Case Summary (G.R. No. L-15459)
Procedural Background
The Union initiated a petition on February 21, 1956, to certify itself as the exclusive bargaining representative for a defined unit of approximately thirty watchmen across the vessels of the Company docked in the Port of Manila. This petition was assigned the docket number Case No. 328-MC. The Court of Industrial Relations later allowed the Maligaya Ship Watchmen Agency to intervene in proceedings that also included related cases against other maritime companies.
Decision of the Court of Industrial Relations
On December 20, 1956, the Court of Industrial Relations issued a decision favoring the Union's certification request. It ordered the Department of Labor to conduct a certification election for the designated bargaining unit. This provision set the operational framework for the election, detailing which employees were eligible to vote and enumerating procedures to address specific concerns regarding certain employees’ eligibility due to pending issues.
Certification Election and Subsequent Orders
The certification election was conducted on January 2, 1959, resulting in a majority vote for the Maligaya Ship Watchmen Agency as the representative of the watchmen. On January 23, 1959, the Court of Industrial Relations issued an order certifying the Agency as the sole representative for collective bargaining on behalf of all employees of the United States Lines Company. This order was contested by the Company, arguing that the scope was improperly expanded to include all laborers, contrary to the specific pleadings that limited representation to watchmen in the Port of Manila.
Motion for Reconsideration
The Company filed a motion for reconsideration on the grounds that the Court's order exceeded the intended scope of representation. Notably, neither the Agency nor the Union opposed this motion. The Court denied the motion on February 19, 1959, asserting the sufficiency of its prior decision without modification.
Legal Issues and Positions
The legal question at the center of the dispute concerned whether the January 23, 1959, order improperly expanded the bargaining unit beyond the designated group of watchmen. The Company contended that the order had indeed expanded the unit to encompass all laborers of the United States Lines Company, while the Union and the lower court maintained that such an expansion was not intended, a
...continue readingCase Syllabus (G.R. No. L-15459)
Case Background
- The case arose from a petition filed by the Associated Watchmen & Security Union (PTWO) on February 21, 1956, before the Court of Industrial Relations, designated as Case No. 328-MC.
- The Union claimed representation over watchmen employed by the United States Lines Company, asserting that they constituted an appropriate and separate bargaining unit.
- It was noted that approximately thirty (30) employees belonged to this unit, with the Union asserting its majority status among them.
- Following the Union's petition, the Maligaya Ship Watchmen Agency was permitted to intervene in the proceedings.
Proceedings and Decisions
- The case was heard jointly with related cases against other companies (American President Lines and Macondray & Co.) and another case involving U.S. Lines Co.
- The Union later amended its petition to restrict its request for certification to the Port of Manila only.
- On December 20, 1956, the Court of Industrial Relations ordered a certification election to be conducted by the Department of Labor for the affected employees, detailing specific voting procedures and criteria.
Certification Election
- The election was conducted o