Title
Pampanga Bus Co., Inc. vs. Pambusco Employees Union, Inc.
Case
G.R. No. 46739
Decision Date
Sep 23, 1939
Court ruled compulsory hiring of union members violates freedom of contract; employers cannot be forced to prefer union hires under Commonwealth Act No. 213.

Case Summary (G.R. No. 46739)

Court's Determination of Authority

The Court determined that the order effectively forced Pampanga Bus Company to preferentially hire union members, which the Court held as exceeding the authority of the Court of Industrial Relations. The ability to make employment decisions freely is an integral element of the liberty of citizens, safeguarded by the due process clause of the Constitution.

Equality of Rights

The ruling emphasized the equality of rights between employers and employees regarding the sale and purchase of labor. The Court noted that compelling either party to act against their will constitutes servitude or oppression. The fundamental principle asserted that employers have the same constitutional rights to select employees as employees have to choose their employers, thereby upholding the essence of personal liberty.

Collective Bargaining Provisions

The decision extensively referenced Section 2 of Commonwealth Act No. 213, which grants labor organizations the right to engage in collective bargaining with employers. The provision recognizes the autonomy of both parties and acknowledges that while unions have the right to advocate for better conditions, there is no legal obligation compelling employers to enter collective agreements with unions. This protection of freedom to contract is crucial to maintaining voluntary agreements between employers and workers without coercion.

Constitutional Guarantees and Precedents

The Court supported its position with various legal precedents and discussions about the nature of collective bargaining as being involuntary. It quoted the Supreme Court of the United States, which stated that the liberties afforded by law extend not merely to union members but also protect employers' rights to hire individuals independently of union allegiance. The principle articulated underscored the importance of voluntary negotiation in achieving labor agreements, rather than imposing agreements or coercive conditions.

Protection Against Intimidation and Coercion

The Court addressed provisions against employer discrimination detailed in Commonwealth Acts that prohibit employers from retaliating against employees for their union activities. However, it clarified that these regulations do not infringe the employers' rights to s

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