G.R. No. L-38955-56 - Confederation of Citizens Labor Unions vs. National Labor Relations Commission

Petitioners: Confederation of Citizens Labor Unions (CCLU), Continental Employees and Laborers Association (CELA), and Redson Employees and Laborers Association (RELA).
Respondents: National Labor Relations Commission (NLRC), Secretary of Labor, Federation of Free Workers (FFW), Continental Manufacturing Corporation (CMC), and Redson Textile Manufacturing Corporation (REDSON).
The case involves a petition for certiorari and prohibition against the NLRC regarding its jurisdiction over certification election cases LR-2751 and LR-2883.
Petitioners sought a preliminary injunction to prevent the scheduled certification election on July 23, 1974.

CMC renewed its collective bargaining agreement with CELA on February 15, 1974, effective until February 15, 1977.
FFW filed a petition for a certification election at CMC on February 12, 1974, before the collective bargaining agreement was acknowledged.
REDSON signed a collective bargaining agreement with RELA on March 4, 1974, which was also filed with the NLRC.
FFW filed a similar petition for REDSON on February 25, 1974, prior to the signing of the collective bargaining agreement.

The NLRC consolidated the petitions for certification elections and ordered elections to be conducted within ten days.
Petitioners filed motions to dismiss the petitions based on the contract-bar rule, arguing that the existing collective bargaining agreements should prevent the elections.
After receiving notice of a pre-election conference, petitioners filed a motion to cancel it, claiming irregularities in the NLRC's actions.

Respondents argued that the scheduled elections were canceled and that the collective bargaining agreements were certified before the petitions were filed.
They contended that the NLRC acted within its jurisdiction and did not commit grave abuse of discretion.
The FFW maintained that petitioners did not raise jurisdictional issues in their motions to dismiss.

Jurisdiction of NLRC: Petitioners argued that the NLRC lacked authority to modify the contract-bar rule, which traditionally prevents certification elections during the life of a collective bargaining agreement.
Certification Requirement: Petitioners contended that the agreements contained substantial benefits and should not require certification to bar elections.
Favoritism: Petitioners alleged that the NLRC favored FFW by allowing it to petition for certification elections.
Grievance Procedure: Petitioners claimed that the NLRC erred by not requiring the grievance procedure to be followed before taking cognizance of the petitions.
Preparation of Decisions: Petitioners argued that the NLRC's decision was void as it was not personally prepared by the Commission members.
Deprivation of Due Process: Petitioners claimed they were denied their day in court as the parties seeking certification were not required to prove their membership claims.
Implementation of Decision: Petitioners alleged that the NLRC attempted to implement its decision before they received a copy of the resolution on their motion for reconsideration.

The NLRC's authority to issue rules regarding collective bargaining agreements is derived from Presidential Decree No. 21, which grants it exclusive jurisdiction over labor disputes.
The NLRC's rules, including the requirement for certification of collective bargaining agreements, are valid and do not violate existing laws.
The petitions for certification elections were valid as they were filed before the collective bargaining agreements were certified.

The NLRC's decision to grant the petitions for certification elections was upheld, as the collective bargaining agreements were not yet certified at the time the petitions were filed.
The NLRC acted within its jurisdiction, and the petitions for certification elections were not barred by the existing agreements.

Allegations of favoritism and irregularities in the NLRC's handling of the petitions were dismissed as errors in judgment...continue reading