Case Summary (G.R. No. 19373)
Facts Leading to the Petition for Declaratory Relief
The petitioners remained members of the United Seamen’s Union until they affiliated with the General Maritime Stevedores Union of the Philippines. As members of the rival union, they joined others in filing, on April 30, 1958, a petition for certification election with the Court of Industrial Relations, seeking to determine which of the two organizations should represent the unlicensed crew members. In May 1958, after learning of the filing, the United Seamen’s Union demanded that the employer terminate the services of the petitioners, asserting that such action was compelled by the closed shop clause in their existing collective bargaining agreement. The petitioners faced the threat of expulsion from their employment.
Declaratory Relief and Temporary Restraint
Faced with that threat, the petitioners went to the Court of First Instance of Manila and filed a petition for declaratory relief with preliminary injunction. They specifically sought a declaration that the closed shop provision relied upon by the respondents was illegal and void. The court granted the injunction on July 25, 1958, directing the respondents to “refrain from terminating the services of the petitioners and ousting them from their lawful employments and positions as unlicensed members of the crew of the vessels of the South Sea Shipping Lines.”
Permanent Injunction After Trial
After trial, the Court of First Instance of Manila, on February 6, 1959, granted the relief prayed for and made the injunction permanent. The case was then elevated to the Supreme Court on appeal from that decision.
Related Certification Election Proceedings and Supreme Court Developments
While the declaratory relief case was pending, the petition for certification election filed in the Court of Industrial Relations was dismissed on the ground that an existing collective bargaining agreement with the United Seamen’s Union still subsisted. An appeal from that dismissal was taken and docketed as G. R. No. L-14689, which the Supreme Court decided on July 26, 1960. In light of that ruling, the Supreme Court later issued a resolution in the present case on April 25, 1967, requiring the parties to show cause why the petition should not be dismissed, because the certification election issues were considered potentially moot.
The Supreme Court’s April 25, 1967 Resolution
The resolution of April 25, 1967 noted that, in L-19373 (Felix Asejo, et al. vs. Adriano Chua Joy, etc. et al.), the earlier Court of Industrial Relations case—later numbered 547-MC and appealed to the Supreme Court as G. R. No. L-14689—had resulted in the Supreme Court ordering that a certification election be held to determine the proper bargaining representative among the two contending unions. The resolution further considered that the certification election “may have already rendered the issues in the instant case moot.” Accordingly, both parties were directed to show cause within fifteen (15) days from notice why the petition should not be dismiss
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Case Syllabus (G.R. No. 19373)
Parties and Procedural Posture
- The individual petitioners were unlicensed crew members employed in vessels owned and operated by respondent Adriano Chua Joy, doing business under South Sea Shipping Lines.
- The respondent United Seamen’s Union of the Philippines acted as the employees’ representative and held a collective bargaining agreement with the employer.
- The respondent South Sea Seamen’s Union of the Philippines was the representative-appellant in the proceedings described in the decision.
- The petitioners became appellees when the case reached the Court of Industrial Relations and later the Supreme Court through appeal.
- The Supreme Court ultimately disposed of the matter by resolution dismissing the petition for failure to show cause after earlier proceedings indicated possible mootness.
Key Factual Allegations
- The collective bargaining agreement executed on June 28, 1957 was intended to last for two years and included a closed shop clause.
- While still members of respondent union, the petitioners affiliated with a rival organization, the General Maritime Stevedores Union of the Philippines.
- On April 30, 1958, the petitioners, as members of the rival union, filed a petition for certification election with the Court of Industrial Relations to determine which organization should represent the unlicensed crew members.
- In May 1958, after learning of the certification election petition, the United Seamen’s Union demanded that the employer terminate the petitioners’ services pursuant to the closed shop agreement.
- Facing the threat of expulsion, the petitioners sought declaratory relief with preliminary injunction from the Court of First Instance of Manila, praying that the closed shop provision invoked by the respondents be declared illegal and void.
- On July 25, 1958, the trial court granted a preliminary injunction ordering respondents to refrain from terminating the petitioners’ services and ousting them from their employment as unlicensed crew members.
- After trial, on February 6, 1959, the trial court granted the relief sought and made the injunction permanent.
- During the pendency of the case, the certification election petition in the Court of Industrial Relations was dismissed on the ground of an existing collective bargaining agreement with the United Seamen’s Union.
- An appeal from the dismissal order was filed and later resulted in a Supreme Court decision requiring a certification election, which the Court considered relevant to mootness.
Litigation History
- The petitioners filed their declaratory relief case in the Court of First Instance of Manila to prevent enforcement of the closed shop clause against