G.R. No. 76185 - Warren Manufacturing Workers Union vs. Bureau of Labor Relations

The controversy arose from an intra-union rivalry between the petitioner, Warren Manufacturing Workers Union (WMWU), and the respondent Philippine Agricultural, Commercial and Industrial Workers Union (PACIWU) that began in 1985.
The dispute centered on which union should be recognized as the exclusive bargaining representative of the rank and file employees of Warren Manufacturing Corporation.

June 13, 1985 – PACIWU filed a petition for certification election, asserting compliance with the jurisdictional requirements.
July 7, 1985 – A motion to dismiss the petition was filed by respondent counsel, arguing the existence of a Collective Bargaining Agreement (CBA) between the employer and the Warren Manufacturing Workers Union (WMWU) that was effective from July 16, 1985 until July 31, 1986.
July 25, 1985 – During conciliation, PACIWU filed a Notice of Strike and a Return-to-Work Agreement was signed.

The agreement provided for a consent election among the rank and file at the company premises on August 25, 1985.
It was further agreed that the certified union in that election would continue to administer the extant CBA until its expiration.

August 12, 1985 – An order was issued by the Ministry directing a consent election, with contending unions being PACIWU, WMWU, and an option for “No Union.”
August 25, 1985 – The consent election was conducted yielding:

PACIWU filed an Election Protest which was later dismissed after a joint motion to dismiss.
In December 1985, a second Notice of Strike was filed by PACIWU, followed by further negotiations that led to the amicable settlement or dismissal of related labor disputes.

June 5, 1986 – PACIWU filed a petition for a certification election.
Shortly thereafter, an additional petition was filed by Samahan ng Manggagawa sa Warren Manufacturing Corporation-Alliance of Nationalist and Genuine Labor Organizations (ANGLO), with both petitions opposed by Warren Manufacturing Corporation on the following grounds:

Lack of the requisite statutory 30% support requirement
The existence of the one-year prohibition on holding a certification election, due to the current CBA

August 18, 1986 – The Med-Arbiter of the National Capital Region, Ministry of Labor and Employment, issued an order:

Mandating a certification election to be held within twenty (20) days to determine the exclusive bargaining representative among the four choices (PACIWU, WMWU, ANGLO, and No Union).
Establishing the mechanics for the process by calling for a pre-election conference.

Following the Med-Arbiter’s order, both Warren Manufacturing Corporation and WMWU filed separate motions (treated as appeals) with the Bureau of Labor Relations, which were subsequently dismissed.
The petition by WMWU was further consolidated with multiple submissions:

The Second Division of the Court, in its November 3, 1986 resolution, issued a temporary restraining order and required respondents to file comments.
PACIWU filed its comment on November 27, 1986.
The public respondent (represented by the Solicitor General) filed its comment on December 10, 1986.
ANGLO filed its comment on December 16, 1986.
WMWU, with the court’s leave, filed a rejoinder on January 6, 1987.
Subsequent memoranda were submitted by all parties between February and March 1987.

Alleging that the certification election was patently premature and illegal.
Arguing that the petitions of the private respondents did not comply with the statutory requirement of 30% support.
Claiming denial of administrative due process due to its exclusion from med-arbitration proceedings.
Contending that the petition was devoid of merit based on the existence of an existing CBA and statutory provisions limiting certification elections.

The petitioner argued that the “one-year no certification election” rule and the Contract Bar Rule (Article 257 of the Labor Code) rendered the certification election improper because:

The existing CBA was valid until July 31, 1986.
The consent election held on August 25, 1985, was merely an arrangement to administer the extant CBA rather than to select a new bargaining agent.

The petitioner maintained that these rules precluded any certification election issues during the life of the existing CBA or within one year of the last certification result.

Whether the certification election ordered by the Med-Arbiter was premature and illegal in light of the existing Collective Bargaining Agreement (CBA) and the “one-year no certification election” rule.
Whether the petitions for certification election filed by PACIWU and ANGLO met the statutory requirement of at least 30% support from the employees in the bargaining unit.
Whether the petitioner, WMWU, suffered a deprivation of administrative due process by being excluded from the med-arbitration proceedings.
Whether the distinctions made by the parties between a consent election and a certification election are valid, particularly in the context of continuing labor relations under an extant CBA.