Case Summary (G.R. No. L-46509)
Background of the Case
- The petitioner, Chrysler Philippines Labor Union (CPLU), is a labor organization registered with the Bureau of Labor Relations since 1965.
- The private respondent, Associated Labor Union (ALU), is a national union with its own registration.
- CPLU affiliated with ALU in March 1974, resulting in a new registration certificate as Chrysler Philippines Labor Union-ALU (CPLU-ALU).
- CPLU-ALU entered into a Collective Bargaining Agreement (CBA) with Chrysler Philippines Corporation (CPC) on March 26, 1974, effective until November 30, 1976.
Dismissal of Certification Election Petition
- An "Urgent Petition for Certification Election" was filed on June 21, 1976, by Rogelio Enriquez and others, which was dismissed by Med-Arbiter Roman A. Tabaquin on September 28, 1976.
- The dismissal was based on three grounds: existence of a CBA, filing too early before the CBA's expiration, and the petition being filed by individuals rather than the union.
- The dismissal was affirmed by Acting Director Francisco Estrella, citing Article 256 of the Labor Code, which restricts certification elections during the life of a CBA.
Subsequent Legal Actions
- On January 17, 1977, CPLU filed a "Petition for Direct Certification with Preliminary Injunction," claiming disaffiliation from ALU and asserting its independent status.
- CPLU-ALU filed motions to intervene and dismiss the petition, arguing that CPLU was non-existent as it had been superseded by CPLU-ALU.
- Med-Arbiter Conrado G. Sagun dismissed CPLU's petition on March 10, 1977, stating that the issue of CPLU's legal personality was prejudicial and unresolved.
Appeal and Responses
- CPLU appealed the dismissal, claiming grave abuse of discretion by the Med-Arbiter.
- The Acting Director affirmed the dismissal, stating that CPLU lacked independent legal personality and needed its own registration certificate to file a petition.
- CPLU subsequently filed a petition for certiorari, alleging that the Acting Director acted without jurisdiction and with grave abuse of discretion.
Temporary Restraining Order and Responses from Respondents
- A temporary restraining order was issued on August 8, 1977, preventing the certification of any CBA between CPLU-ALU and CPC.
- CPC maintained neutrality in the representation issue, while the Solicitor General sided with CPLU, expressing regret over the Acting Director's position.
- CPLU-ALU contended that CPLU was not a registered union and that decisions of the Bureau of Labor Relations Director were not subject to judicial review.
Legal Personality of CPLU
- The Court agreed with the Solicitor General that CPLU retained its legal personality to file a petition for certification election despite disaffiliation from ALU.
- The Labor Code does not stipulate that a registered local union loses its legal personality upon affiliation or disaffiliation.
- The Court referenced previous rulings affirming that disaffiliation does not negate a union's status as a legitimate labor organization.
Mootness of Representation Issue
- The Court found no merit in CPLU-ALU's claim that the representation issue became moot due to the ratification of a new CBA by the majority of hourly-paid employees.
- The ratification was not intended to choose an exclusive bargaining representative but to adopt terms from another CBA.
- The execution of a new CBA does not preclude the need for a certification election to determine the true representative of the employees.
Judicial Review of Bureau of Labor Relations Decisions
- The Court reaffirmed its jurisdiction to review decisions of the Bureau of Labor ...continue reading