Case Summary (G.R. No. L-19791)
Procedural Background
The Respondents sought reconsideration of a prior decision which noted deficiencies regarding the submission of a certification concerning the regularity of dues collection from union members. It was determined that this certification was presented after the hearing concluded without allowing the Respondents the opportunity to cross-examine the certifying officers, thereby raising concerns about the adherence to due process.
Legal Framework
The applicable legal provision in this case is found in Section 5(b) of Republic Act 875, which allows the court to consider evidence beyond what was presented during initial hearings. However, this provision does not absolve the court from ensuring that due process is observed, particularly allowing the Respondents the chance to challenge the evidence presented against them.
Rationale for Remanding the Case
The court recognized that the questioned resolutions were relevant to the disputes raised in the Respondents’ complaint. It emphasized that having these resolutions properly admissible as evidence would further the goals of truth and justice, allowing for a comprehensive evaluation of the case.
Respondents’ Position
In response to the remanding, the Respondents expressed a willingness to waive their right to challenge the evidence, adopting a stance that assumes the genuineness and veracity of the submitted certification and resolutions. They did this to expedite the case's resolution without unnecessary delays.
Union Constitution and Bylaws
The Respondents referenced Section 6, Article X of the union's constitution and by-laws, which delineates procedures for the passage of resolutions. They challenged the legality of Resolution No. 1, which sought to increase contributions from members, asserting it had not been approved per the constitutional requirements that mandate a two-thirds majority for amendments.
Court's Evaluation of the Amendments
Upon reviewing the provisions and the approval process of Resolution No. 1, the court acknowledged that the resolution was indeed passed by a simple majority rather than the required supermajority. Consequently, this determination led the court to conclude that Resolution No. 1 was illegally enacted.
Accounting Issue
With respect to the accounting presented by the union president regarding travel expenses, the Respondents opposed the approval, claiming that supp
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Case Citation
- Reference: 133 Phil. 594; 64 OG 8830 (August, 1968)
- Docket Number: G.R. No. L-19791
- Date of Decision: August 14, 1968
Background of the Case
- The case involves a petition filed by the Kapisanan ng mga Mangagawa sa Manila Railroad Company against Rafael Hernandez and others.
- The primary issue revolves around the collection of additional dues from union members and the regularity of the resolutions supporting this collection.
- Respondents sought reconsideration of a previous decision which remanded the case to the Court of Industrial Relations for further evidence gathering.
Procedural History
- The initial decision was made based on the certification from the union's convention chairman and secretary, which was not subjected to cross-examination by the respondents.
- The Court acknowledged that while it could consider evidence beyond the hearing, due process rights must still be respected, necessitating the opportunity for respondents to contest the certification's validity.
Key Issues
- The validity and regularity of the resolutions concerning the collection of additional dues.
- The legal requirement for the approval of amendments to the union’s constitution and by-laws as dictated by the union's governing documents.
Findings and Rationale
- The Court found that the resolutions refer