Title
Chrysler Philippines Labor Union vs. Estrella
Case
G.R. No. L-46509
Decision Date
Nov 16, 1978
CPLU retained legal personality post-disaffiliation from ALU; CBA ratification didn’t moot certification election; Supreme Court affirmed judicial review of BLR decisions.
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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  • CPLU-ALU filed motions to intervene and dismiss the petition, arguing that CPLU was non-existent as it had been superseded by CPLU-ALU.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

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