Case Summary (G.R. No. L-58595)
Petitioner
Agricultural Credit and Cooperative Financing Administration (ACCFA), subsequently reorganized as Agricultural Credit Administration (ACA) under the Land Reform Code.
Respondents
ACCFA Supervisors’ Association (ASA), ACCFA Workers’ Association (AWA), Confederation of Unions in Government Corporations and Offices (CUGCO), and the Court of Industrial Relations (CIR).
Key Dates
- July 1 1961–June 30 1962: Term of collective bargaining agreement (CBA)
- September 4 1961: Execution of CBA between ACCFA and the two unions
- October 25–November 26 1962: Strike by union members
- October 30 1962: Filing of unfair labor practice complaint (Case No. 3450-ULP)
- March 25 1963: CIR decision ordering ACCFA to implement CBA and cease unfair labor practices
- August 8 1963: Enactment of Republic Act No. 3844 (Land Reform Code), renaming ACCFA to ACA
- March 17 1964: Petition for certification election filed with CIR (Case No. 1327-MC)
- May 21 1964: CIR order certifying ASA and AWA as exclusive bargaining agents
- October 6 1964: Supreme Court stay of CIR’s certification order
- November 29 1969: Supreme Court decision on both appeals
Applicable Law
- Republic Act No. 821 (Creation of ACCFA)
- Republic Act No. 3844 (Agricultural Land Reform Code)
- Republic Act No. 875 (Labor Code provisions on public‐sector strikes)
- Revised Administrative Code, Sec. 79(D) (Presidential appointment power)
- Executive Order No. 75 (1964 reorganization under Land Reform Project Administration)
Background of the 1961 Collective Bargaining Agreement
The ACCFA entered into a one-year CBA with ASA and AWA, covering wages, fringe benefits, and living allowances. Within months, the unions alleged non-compliance, culminating in a strike (October 25 to November 26, 1962).
Unfair Labor Practice Proceedings (G.R. No. L-21484)
The unions and CUGCO filed a complaint alleging:
- Discouragement of self-organization
- Discrimination in promotions
- Refusal to bargain in good faith
ACCFA denied jurisdiction, challenged the CBA’s legality and presidential approval requirement, and contended the CBA had lapsed. The CIR rejected these defenses and ordered ACCFA to:
- Cease acts discouraging union rights
- Implement the CBA (including a ₱30 living allowance)
- Bargain expeditiously and in good faith
Issues on Appeal in G.R. No. L-21484
- CIR’s jurisdiction—whether ACCFA exercises governmental or proprietary functions
- Validity, term, and enforceability of the CBA and its fringe benefits
- Legal and factual basis for unfair labor practice findings
- CIR’s competence to enforce an expired CBA
Certification Election Proceedings (G.R. No. L-23605)
After ACCFA’s conversion into ACA under the Land Reform Code, ASA and AWA petitioned for certification as exclusive bargaining agents. The CIR initially directed ACA to respond; ACA challenged jurisdiction, representation, and union membership legality. A joint manifestation conceded majority representation, and CIR certified both unions by order of May 21, 1964, later affirmed en banc.
Issue on Appeal in G.R. No. L-23605
Whether ACA performs governmental functions (precluding CIR jurisdiction under public-sector strike prohibition) or proprietary functions (allowing certification and collective bargaining).
Supreme Court Analysis – Nature of ACA’s Functions
- Land Reform Code Sections 110–118 empower ACA with regulatory, credit-extension, audit (visitorial) and enforcement powers, appropriation of public funds (₱150 million), rediscount privileges, and tax exemptions.
- Executive Order No. 75 placed ACA personnel in a unified Land Reform Project Administration, subject to Civil Service law, standardized positions, and presidential appointment power under Revised Administrative Code Section 79(D).
- Senate debates confirmed ACA’s role as a non-profit, government-lender and policy instrument for land reform.
These features establish a purely governmental character, not proprietary, aligned with state policy to implement land reform and social justice under the then Constitution.
Effect on Collective Bargaining and Strike Rights
By exercising governmental functions, ACA falls within the prohibition of Section 11, Republic Act No. 875, which bars strikes and collective bargaining over terms and conditions of employment in governmental agencies. Therefore, ASA and AWA cannot be certified or compel ACA to bargain collectively.
Ruling on the Unfair Labor Practice Case
With ACA’s reorganization into a government office performing sovereign functions, the CIR order to bargain and other remedial commands became moot and academic. The only surviving issue concerns fringe benefits under the September 4, 1961 C
Case Syllabus (G.R. No. L-58595)
Parties
- Petitioner in G.R. No. L-21484: The Agricultural Credit and Cooperative Financing Administration (ACCFA)
- Petitioner in G.R. No. L-23605: The Agricultural Credit Administration (ACA), successor of ACCFA
- Respondents in L-21484: Confederation of Unions in Government Corporations and Offices (CUGCO), ACCFA Supervisors’ Association (ASA), ACCFA Workers’ Association (AWA), and the Court of Industrial Relations (CIR)
- Respondents in L-23605: ACCFA Supervisors’ Association (ASA), ACCFA Workers’ Association (AWA), and the CIR
Statutory and Institutional Background
- ACCFA created by Republic Act No. 821, as amended, to extend credit and cooperative financing to agriculture
- Under Republic Act No. 3844 (Land Reform Code), ACCFA reorganized and renamed Agricultural Credit Administration (ACA)
- ASA and AWA: labor organizations of supervisors and rank-and-file employees of ACCFA/ACA
- CIR: tribunal empowered to hear unfair labor practice (ULP) complaints and certification election petitions under Republic Act No. 875
Facts – G.R. No. L-21484 (ULP Complaint)
- September 4, 1961: ASA and AWA enter into a one-year collective bargaining agreement (CBA) with ACCFA, effective July 1, 1961–June 30, 1962
- Early 1962: Unions protest alleged violations and non-implementation of CBA provisions
- October 25, 1962: Unions declare a strike; strikers return voluntarily November 26, 1962
- October 30, 1962: Unions and CUGCO file ULP complaint (Case No. 3450-ULP) alleging:
• Discouragement of self-organization rights
• Discrimination in promotions
• Refusal to bargain collectively
Procedural History – G.R. No. L-21484
- ACCFA raises defenses: lack of CIR jurisdiction, illegality/expiration of CBA, no Presidential approval of fringe benefits
- CIR Decision (March 25, 1963): ACCFA ordered to:
- Cease acts discouraging union self-organization
- Implement CBA provisions (including P30 living allowance)
- Bargain in good faith, expeditiously with the Unions
- CIR En banc Resolution (April 25, 1963): Denies ACCFA motion for reconsideration
- ACCFA files certiorari (G.R. No. L-21484) to Supreme Court
Issues Raised – G.R. No. L-21484
- CIR jurisdiction: whether ACCFA performed governmental or proprietary functions
- Validity and enforceability of CBA: has it lapsed; fringe benefits approval
- Basis for ULP findings and orders
- Competence of the Court to enforce an expired CBA
Facts – G.R. No. L-23605 (Certification Election)
- August 8, 1963: Land Reform Code (R.A.3814) enacted, ACCFA becomes ACA
- March 17, 1964: ASA and AWA file petition for certification election (Case No. 1327-MC) before CIR, seek