Case Summary (G.R. No. L-41106)
Central Legal Issue
Whether Article 226 of the New Labor Code provides statutory authorization for the Bureau of Labor Relations (and its officers) to order and conduct a referendum election among union members to determine affiliation with a federation, or whether such an order exceeded statutory jurisdiction and amounted to grave abuse of discretion.
Text and Intended Scope of Article 226
Article 226 vests the Bureau of Labor Relations and regional Labor Relations Divisions with “original and exclusive authority” to act, either on their own initiative or upon request, on all inter‑union and intra‑union conflicts and disputes affecting labor‑management relations in all workplaces, except for disputes arising from implementation or interpretation of CBAs (which are reserved for grievance procedures or voluntary arbitration). The Court reads the language to be broad and inclusive, emphasizing the statute’s express grant of original and exclusive competence.
Government Counsel’s Position and Persuasiveness
The Acting Solicitor General (assisted by other government counsel) argued that the wording of Article 226 sustains the Bureau’s authority to act in matters such as the present controversy. The Court found this view considerably persuasive, noting that a narrow or restrictive construction would frustrate the Labor Code’s basic objective of entrusting the Department of Labor and its bureaus with the competence to decide labor controversies and thereby minimize judicial intervention.
Statutory Interpretation: Purpose and Rule of Construction
The Court applied a purposive approach to statutory interpretation: legislative words are to be read in light of the statute’s end — here, promoting industrial peace and advancing constitutional objectives of social justice and protection of labor. Quoting jurisprudential authorities, the opinion stresses that interpretation should effectuate the statute’s purpose rather than defeat it by narrow literalism. The Court held that Article 226’s “original and exclusive” grant of authority should not be confined by a strained reading; to do so would undermine the Labor Code’s policymaking function and administrative competence.
Abuse of Discretion Analysis and Appropriateness of a Referendum
On the question of whether the Bureau’s ordering of a referendum constituted grave abuse of discretion, the Court found no such abuse. The dispute concerned the factual question of whether the union members had decided to affiliate contrary to their president’s stance — a question best resolved directly by a referendum. The Court emphasized that the guarantee of fairness rests on the Bureau’s impartiality and neutrality, and the petitioner had not shown any reason to doubt the Bureau’s neutrality. The Court further noted that similar imprecations of arbitrariness had been consistently rejected in prior certification election cases; holding an election to determine employee wishes has been repeatedly endorsed as a proper administrative tool to obtain definitive proof of collective intent.
Reliance on Precedent and Analogous Decisions
The Court relied on the policy and precedent that administrative agencies with statutory competence may order elections to resolve union representation and affiliation disputes. The opinion references an array of prior decisions (as cited in the record) where elections or similar administrative determinations were upheld in analogous contexts, reinforcing that an election is an accepted and appropriate means to ascertain employee choice and that judicial nullification is unwarranted absent a showing of grave abuse.
Disposition and Concurrences
The petition for certiorari was dismissed and the Bureau’s order was sustained; the decision was immediately executory. Justices Barredo, Concepcion Jr., and Santos concurred. Justice Antonio concurred specifically on the ground that the
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Case Citation and Court
- Citation: 169 Phil. 91, SECOND DIVISION, G.R. No. L-41106, September 22, 1977.
- Decision authored by Justice Fernando.
- Vote/Concurrences: Barredo, Concepcion Jr., and Santos, JJ., concur. Antonio, J., concurs for a statutory-authority ground. Aquino, J., concurs on the ground of mootness (related to a 1975 petition of FFW for a certification election).
- Counsel noted in the recitation of the Solicitor General's comment: Acting Solicitor General Hugo E. Gutierrez, Jr., assisted by Assistant Solicitor General Reynato S. Puno and Solicitor Romeo C. de la Cruz. [2]
Procedural Posture
- Nature of proceeding: Petition for certiorari and prohibition (original petition to the Court).
- Relief sought by petitioner: Nullification of an administrative order issued by respondent George A. Eduvala (Officer-in-Charge, Bureau of Labor Relations) requiring that a referendum election be held among members of the Litex Employees Association to determine whether they wished affiliation with the Federation of Free Workers (F.F.W.).
- Lower administrative action being challenged: Order of the Officer-in-Charge of the Bureau of Labor Relations affirming the Compulsory Arbitrator’s conclusion that a referendum election should be held.
Facts
- Petitioner: Litex Employees Association, a labor union of employees of Lirag Textile Mills, Inc. (referred to as petitioner labor union).
- Respondents: George A. Eduvala in his capacity as Officer-in-Charge, Bureau of Labor Relations, Department of Labor; and the Federation of Free Workers (F.F.W.).
- Origin of controversy: A petition filed by F.F.W. with the Bureau of Labor Relations requesting a referendum among members of the Litex Employees Association to determine their desire to affiliate with F.F.W.
- Allegations by F.F.W.: That a "great majority" of union members desired affiliation but that the union President (named Johnny de Leon) opposed such affiliation.
- Contentions by the petitioner union: Only about 700 out of more than 2,200 employees of the company had manifested desire to affiliate with F.F.W.; a substantial number of those had since repudiated their signatures; and what was sought by F.F.W. amounted to a certification election which the union asserted was improper because there was a certified collective bargaining agreement (CBA) between the union and the company.
Legal Question Presented
- Decisive issue: Whether the Officer-in-Charge of the Bureau of Labor Relations had statutory authority to require and conduct a referendum election among the union members to ascertain their wishes regarding affiliation with F.F.W.—i.e., whether there was statutory authorization for such a referendum election.
Contested Statutory Provision (Article 226, New Labor Code, 1974)
- Quotation of Article 226 as cited in the case:
- "The Bureau of Labor Relations and the Labor Relations Division in the regional offices of the Department of Labor shall have original and exclusive authority to act. at their own initiation or upon request of either or both parties, on all inter-union and intra-union conflicts, and all disputes, grievances of problems arising from or affecting labor-management relations in all workplaces, whether agricultural or non-agricultural, except those arising from the implementation or interpretation of collective bargaining agreements which shall be the subject of grievance procedure and/or voluntary arbitration." [1]
Positions of the Parties and Supporting Authorities
- Petitioner Union’s position:
- There is no statutory authorization for holding the referendum election.
- The remedy sought by F.F.W. was essentially a certification election; certification election was improper given the existence of a certified collective bargaining agreement between the union and the company.
- Factual contention that only about 700 of over 2,200 employees initially manifested desire to affiliate and that many had repudiated signatures.
- Respondent Bureau of Labor Relations / Officer-in-Charge’s position (as supported by the Acting Solicitor General):
- Article 226 was cited as authorizing the Bureau to act, at its own initiation or upon request of parties, on inter-union and intra-union conflicts and disputes affecting labor-management relations.
- The Acting Solicitor General Hugo E. Gutierrez, Jr. (with assistants) maintained that the wording of Article 226 sustains the authority exercised by the Bureau i