Title
San Beda College vs. Court of Industrial Relations
Case
G.R. No. L-7649
Decision Date
Oct 29, 1955
San Beda College, a non-profit educational institution, contested CIR jurisdiction over NLU's wage demands, arguing its operations were non-industrial. Supreme Court ruled CIR lacked jurisdiction, dismissing the petition.

Case Summary (G.R. No. 187604)

Sequence of Events

On December 16, 1952, the National Labor Union filed demands for wage increases and other concessions from San Beda College. When these demands were not met, the union formally petitioned the Court of Industrial Relations on January 20, 1953. Subsequently, San Beda College moved to dismiss the petition, arguing that the reduction in membership of the labor union (from 46 to less than 30) negated the union's standing to file the petition. The Court denied this dismissal on August 1, 1953, reasoning that the jurisdiction was established upon the submission of the petition before any withdrawal of members occurred.

Jurisdiction and Dismissal Motions

On August 10, 1953, San Beda College filed a motion for reconsideration on the grounds that the dispute did not qualify as an industrial dispute and involved fewer than thirty employees. The motion for rehearing was denied, and the Court determined that it was imperative for the college to present evidence to clarify its characterization as an educational institution rather than an industrial one. The hearings continued, with motions for dismissal and reconsiderations taking place, focusing on whether the case pertained to an industrial or agricultural dispute under Commonwealth Act No. 103 and its amendments.

Educational Institution vs. Industrial Pursuit

The Court examined whether San Beda College was engaged in industrial activity under the definition provided by relevant laws. The evidence demonstrated that San Beda College served as an educational establishment, focusing on the education and development of young men, and not designed primarily for profit generation. Testimonies and documents supported the assertion that the college, operated by the Benedictine Order, was not profit-driven, which further strengthened the case that the labor dispute was not an industrial dispute as defined by law.

Judicial Findings

The Court rejected the notion that the employment disputes of those working at San Beda College fell under the jurisdiction of the Court of Industrial Relations, adhering to pre

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