Case Summary (G.R. No. L-31676)
Background and Procedural History
On December 28, 1966, a petition was filed by employees of the Philippine Packing Corporation seeking a certification election. The Court of Industrial Relations issued an order on January 10, 1969, mandating this election. However, subsequent to this order, the company and the union contested the eligibility list provided, citing changes in the workforce since December 31, 1966. The Court, in a resolution dated June 11, 1969, modified the basis for the eligibility list to include payrolls from December 31, 1968, alongside the earlier payrolls. The company's appeal against this resolution was dismissed for lack of merit in September 1969.
Motions Filed and Responses
Despite the court’s resolution being final and executory, the respondent union submitted a motion on February 4, 1970, requesting the inclusion and exclusion of certain employees in the eligibility list. Moreover, another motion was filed on behalf of 504 alleged employees claiming “regular and permanent status.” The petitioner opposed these motions, contending that they sought to reopen a matter that had already been conclusively decided.
Respondent Judge's Order and Legal Issues
On February 16, 1970, Judge Tabigne issued an order cancelling the scheduled election. He cited the necessity to resolve the pending motions before proceeding, claiming uncertainty regarding his jurisdiction over the motions. This order prompted the petitioner to file a writ of certiorari and prohibition to challenge the judge's decision, which delayed the election indefinitely.
The Court's Rulings on Jurisdiction
The court articulated that Judge Tabigne acted beyond his authority and jurisdiction by canceling the election and entertaining motions meant to revisit the established number of eligible voters. The industrial court had already resolved these issues in its June 11, 1969 resolution, which became final when the Supreme Court dismissed the company's appeal, rendering the eligibility list conclusive.
Legal Principles Applied
The Court emphasized that under Section 12(c) of the Industrial Peace Act (Republic Act No. 875), the conduct of elections was mandatory upon receiving a petition signed by a requisite percentage of employees. Given the extensive delays in conducting the election—which was set against years of litigation—the Court found it in
...continue readingCase Syllabus (G.R. No. L-31676)
Case Overview
- This case is an original action for certiorari and prohibition with a preliminary injunction against the order of respondent judge, which suspended the scheduled certification election for employees of Philippine Packing Corporation.
- The case originated from a petition for a certification election filed by the employees of the Philippine Packing Corporation on December 28, 1966.
- The certification election was initially ordered by respondent judge on January 10, 1969, prompting motions for reconsideration from both the company and the union regarding the list of eligible voters.
Background of the Case
- The initial order for the certification election was contested due to claims of changes in the employee roster since the payrolls used to determine eligible voters were dated December 31, 1966.
- The Court of Industrial Relations, in a resolution dated June 11, 1969, clarified that payrolls as of December 31, 1968, should also be included to determine eligible voters, thus modifying the earlier payroll basis.
- The Labor Department scheduled the election for February 20, 1970, following the resolution that mandated the holding of the election.
Respondent Union's Motions
- On February 4, 1970, the respondent union filed motions to include 110 alleged employees and exclude others from the list of eligible voters, claiming changes in employee status that should be recognized.
- Additionally, a motion to intervene