Case Summary (G.R. No. L-12222)
Jurisdiction of the Court of Industrial Relations
On January 2, 1957, Judge Jose S. Bautista of the Court of Industrial Relations determined that while the trial could not progress without a preceding preliminary investigation, the Court retained jurisdiction over the controversy regarding unfair labor practices. This determination was primarily based on the view that the nature of employment in industrial cases was not a definitive criterion for the jurisdiction of the Court in such matters. The ruling ordered the case to be referred to the Prosecution Division for the required preliminary investigation.
Arguments by the Parties
The University of San Agustin contested the jurisdiction of the Court, arguing that college professors are not "industrial" laborers, and that the Philippine Association of College and University Professors failed to qualify as a legitimate labor organization. Citing various legal precedents, the University posited that since it operated not for profit or gain, its relationship with faculty members did not constitute that of employer and employee as defined under applicable labor laws. The University argued that the underlying controversy was not an "industrial" dispute, thereby challenging the authority of the Court of Industrial Relations to address the matter.
Analogy to Prior Case Law
A pivotal reference in the legal discussion is the case of Boy Scouts of the Philippines vs. Juliana V. Araos, where the Supreme Court ruled against the application of labor laws to organizations not created for profit. The decision underscored that labor legislation was meant to address the relations between employers engaged in profit-seeking enterprise and their employees, excluding entities founded primarily for charitable, educational, or similar higher purposes. Given the University of San Agustin's non-profit educational nature, the Supreme Court found a parallel with the aforementioned case.
Conclusive Ruling
In lig
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Case Background
- The case involves a petition for review of an order from the Court of Industrial Relations dated January 2, 1957, and a subsequent resolution dated March 5, 1957.
- The order declared that the Court had jurisdiction over the controversy and ordered a referral to the Prosecution Division for a preliminary investigation.
- The underlying complaint was filed by the Philippine Association of College and University Professors against the University of San Agustin, alleging unfair labor practices.
- The University of San Agustin denied the allegations and contested the jurisdiction of the Court of Industrial Relations over both the parties involved and the subject matter.
Legal Proceedings
- A trial was held before a hearing examiner, which proceeded despite the respondent's assertion regarding the lack of a preliminary investigation.
- Judge Jose S. Bautista issued an order acknowledging the need for a preliminary investigation but asserting the Court's jurisdiction over the issue based on industrial employment not being a basic criterion for jurisdiction in unfair labor practice cases.
- The order was affirmed by the court en banc, with one judge abstaining and another concurring only in the result.
Parties Involved
- Petitioner: University of San Agustin, a religious non-stock corporation established for educational purposes and not for profit.
- Respondent: Philippine Association of College and University Professors, a non-stock association representing educators in various