Case Summary (G.R. No. L-76959)
Petitioner and Respondent Overview
The petitioners are:
- Batangas-I Electric Cooperative Labor Union (G.R. No. 62386)
- Bulacan II Electric Cooperative, Inc. (G.R. No. 70880)
- Albay Electric Cooperative I (G.R. No. 74560)
The respondents include the public officers from the Bureau of Labor Relations and the respective electric cooperatives.
Applicable Law
The core legal issue revolves around the interpretation of Article 243 of the Labor Code, as amended, concerning the right of employees to self-organization and the formation of labor unions, particularly in the context of electric cooperatives.
Background of G.R. No. 62386
Batangas-I Electric Cooperative Labor Union filed a petition for a certification election asserting its legitimacy as a labor organization to represent the employees of Batangas-I Electric Cooperative, Inc. The cooperative argued against the election, citing that employees who are also cooperative members could not form a labor union. The Bureau of Labor Relations upheld this assertion, concluding that cooperative members are co-owners and therefore lack the status of employees concerning union formation.
Determination and Conclusions in G.R. No. 62386
The Supreme Court affirmed the Bureau of Labor Relations' decision, stating that employees who are also members of a cooperative cannot engage in collective bargaining since they essentially bargain with themselves as co-owners. The ruling further indicated that cooperative members cannot invoke rights to collective bargaining under existing laws due to their co-ownership status.
Background of G.R. No. 70880
The Federation of Free Workers (FFW) sought to represent Bulacan II Electric Cooperative's employees for collective bargaining. The cooperative contended that the petition did not meet the necessary jurisdictional requirement of 30% employee support since some employees were cooperative members, hence disqualified under the same reasoning as in G.R. No. 62386.
Determination and Conclusions in G.R. No. 70880
The Supreme Court again upheld the decision of the Bureau of Labor Relations, which found that despite the cooperative membership, a sufficient number of non-member employees supported the petition. Thus, the right to organize and form a union was reaffirmed for those disqualified under previous interpretations of ownership.
Background of G.R. No. 74560
The Federation of Free Workers, representing Albay Electric Cooperative I's employees, filed a similar petition for a certification election. The cooperative contested the jurisdictional requirement, arguing that many petition signatories were cooperative members and thus could not be counted toward the 30% requirement for a valid petition.
Determination and Conclusions in G.R. No. 74560
The Supreme Court reversed the Bureau of Labor Relations’ decision in this case, asserting that only the majority non-member employees could validly support union formation. With insufficient signatures from qualified employees, it ruled against the holding of a certification election due to the failure to meet the necessary jurisdictional requirement.
Final Judgment Summary
- G.R. No. 62386: The petition was dismissed and the Bureau of
Case Syllabus (G.R. No. L-76959)
Case Overview
- This syllabus encompasses three separate petitions for certiorari under Rule 65 of the Rules of Court, relating to the eligibility of employees of electric cooperatives to form or join labor organizations for collective bargaining purposes.
- The cases are identified as follows:
- G.R. No. 62386: Batangas-I Electric Cooperative Labor Union vs. Romeo A. Young, et al.
- G.R. No. 70880: Bulacan II Electric Cooperative, Inc. vs. Hon. Eliseo A. Penaflor, et al.
- G.R. No. 74560: Albay Electric Cooperative I vs. Cresenciano B. Trajano, et al.
G.R. No. 62386 Background
- On June 1, 1981, the Batangas-I Electric Cooperative Labor Union (the Union) filed a petition for a certification election alleging:
- Its legitimacy as a labor organization.
- That the Batangas-I Electric Cooperative Inc. (BATELEC) has approximately 150 employees.
- There were no other unions or existing collective bargaining agreements within BATELEC.
- The Med-Arbiter initially approved the petition, ordering a certification election.
- BATELEC contested, asserting that union formation within a cooperative is illegal since the employees are also part-owners, referencing Section 35 of Presidential Decree (PD) 269.
G.R. No. 62386 Decision
- The Officer in Charge of the Bureau of Labor Relations ruled that employees who are also members of the cooperative cannot form or join a labor organization.
- The ruling was based on:
- The nature of cooperatives as non-profit organizations primarily for mutual aid among members.
- The assertion that employees/members enjoy benefits indicative of ownership.
- The distinction between self-employed individuals allowed to form unions and cooperative members excluded from collective bargaining due to their ownership status.
- The Union's petition was ultimately dismissed, affirming the Bureau's decision.