Case Summary (G.R. No. 77951)
Factual Background
The Cooperative Rural Bank of Davao City, Inc., a cooperative banking entity situated in Davao City and partially owned by the government, has 16 rank-and-file employees. Notably, in August 1986, these employees had no existing collective bargaining agreement with the bank. On August 27, 1986, the Federation of Free Workers, a labor organization duly registered with the Department of Labor and Employment, submitted a verified petition for a certification election concerning the rank-and-file employees of the petitioner.
Procedural History
An order granting the petition for certification election was issued by the Bureau of Labor Relations on September 18, 1986. The Cooperative Rural Bank subsequently filed an Appeal Memorandum on October 3, 1986, disputing the order based on their assertion that cooperatives do not fall under the rules governing certification elections because they are not profit-driven institutions and claimed that two employees seeking the certification were actually managerial staff. Despite the appeal, the Bureau affirmed its earlier order on February 11, 1987, leading to further motions and ultimately the case being escalated to the Supreme Court on April 9, 1987.
Legal Issues Presented
The core legal issue revolves around whether employees of a cooperative can actually organize for collective bargaining given that they are also co-owners of the organization. The petitioner contended that collective bargaining was not applicable as employees of cooperatives, who are also members, inherently cannot negotiate with themselves.
Applicable Law
Article 243 of the Labor Code stipulates that all employees, irrespective of the type of enterprise they are in, have the right to self-organization for collective bargaining purposes. However, managerial employees are disqualified from this right as established in Article 245. The context of cooperatives is further elucidated in Presidential Decree No. 175, defining cooperatives and outlining their operating principles.
Findings and Rationale
The Supreme Court ultimately found merit in the petition. It clarified that while all rank-and-file employees of a cooperative who are not classified as managerial are eligible to form labor organizations, the context surrounding cooperatives is unique. Cooperatives are inherently different from standard business entities as their members are part owners, which complicates the scenario of collective bargaining.
The Solicitor General's stance, which suggested that the petition was moot due to the certification election occurring, was rejected on the grounds that the issues at hand involved potential jurisdictional errors
...continue readingCase Syllabus (G.R. No. 77951)
Case Overview
- The case involves a Petition for certiorari under Rule 65 of the Rules of Court.
- The primary issue is whether employees of a cooperative can organize for collective bargaining.
- The petitioner, Cooperative Rural Bank of Davao City, Inc., operates in Davao City and is partially government-owned with 16 rank-and-file employees.
- A labor organization, the Federation of Free Workers, sought to represent these employees for collective bargaining.
Procedural History
- On August 27, 1986, the Federation of Free Workers filed a verified Petition for certification election for the rank-and-file employees, which was granted by the Bureau of Labor Relations on September 18, 1986.
- The petitioner appealed the Order, arguing that cooperatives are not covered by certification election rules and that some employees were managerial and thus disqualified from forming a labor organization.
- The Bureau of Labor Relations affirmed its decision on February 11, 1987, dismissing the petitioner’s appeal.
Petitioner’s Arguments
- The petitioner contended that cooperatives, being non-profit organizations, do not fall under the certification election rules.
- It claimed that two employees involved were actually managerial, thus barred from union activities under Article 245 of the Labor Code.
- The petitioner cited an Opinion from the Solicitor General stating that employees who are also members/co-ow