Case Summary (G.R. No. 121157)
Petitioner and Respondent
Petitioner: Elizalde Rope Workers’ Union
Respondent: Benjamin Victoriano
Key Dates
• 1958 – Victoriano begins employment and union membership.
• March 3–4, 1964 – Renewal of collective bargaining agreement with closed‐shop clause.
• June 18, 1961 – Republic Act No. 3350 amends RA 875 to exempt members of sects prohibiting union affiliation.
• September 3, 1964 – Victoriano reiterates resignation from the Union.
• August 26, 1965 – Court of First Instance (CFI) issues injunction preventing dismissal and awards P500 attorney’s fees.
• September 12, 1974 – Supreme Court decision affirming CFI.
Applicable Law
• Republic Act No. 875 (Industrial Peace Act) Section 4(a)(4) as amended by RA 3350.
• 1973 Philippine Constitution provisions on freedom of association (Art III §1(6), Art IV §7), religious freedom (Art III §1(7), Art IV §8), contract impairment, equal protection, social justice, and protection of labor (Art II §5).
Facts
The collective bargaining agreement required union membership as a condition of employment (closed shop). Victoriano, bound by his sect’s prohibition against union affiliation, tendered resignation in 1962 and again in 1964. The Union demanded his dismissal under the closed‐shop clause; the company warned Victoriano he would be terminated unless he rejoined or reached an arrangement with the Union. Victoriano secured a CFI injunction against both the Union and the company.
Procedural History
CFI Manila enjoined the company from dismissing Victoriano and ordered the Union to pay P500 attorney’s fees. The Union appealed to the Supreme Court on pure questions of law: (1) constitutionality of RA 3350; (2) propriety of attorney’s fees award.
Constitutional Presumptions
Statutes enjoy a presumption of constitutionality; challengers must prove invalidity beyond reasonable doubt. Reasonable legislative exercises of police power that serve general welfare may modify or abrogate existing contract terms without violating constitutional contract clauses.
Freedom of Association
RA 3350 does not forbid sect members from joining unions; it merely exempts them from closed‐shop enforcement. This upholds the dual right to join or abstain from associations, as guaranteed by the Constitution and RA 875, by preventing coercion where religious belief opposes union membership.
Contract Impairment
The amendment to RA 875 altered closed‐shop obligations by exempting certain sect members, thereby impairing existing contracts. However, the impairment is justifiable under police power to protect religious freedom and the right to work. Contracts are made subject to valid future legislation of general welfare.
Establishment and Free Exercise
RA 3350 serves a secular purpose—preventing religious discrimination in employment—and its primary effect neither advances nor inhibits religion. Incidental benefits to religious sect members do not violate the Establishment Clause. The law balances collective labor rights with the fundamental right to free exercise of religion.
Religious Test
No religious test is imposed as a condition to join or resign from any association. Sect members are ipso jure exempted from closed‐shop coverage without any required positive act, thereby avoiding any religious qualification for civil rights.
Equal Protection
Classification based on membership in sects that prohibit union affiliation is reasonable and germane to the law’s purpose. It rests on substantial distinctions in religious beliefs and applies equally to all within the defined class. Inequality inherent in classification does not offend
...continue readingCase Syllabus (G.R. No. 121157)
Factual Background
- Benjamin Victoriano, a member of the Iglesia ni Cristo, had been employed by Elizalde Rope Factory, Inc. since 1958.
- As a permanent employee, Victoriano was covered by a collective bargaining agreement between the Company and the Elizalde Rope Workers’ Union, containing a closed‐shop clause requiring union membership as a condition of employment.
- The agreement expired on March 3, 1964, but was immediately renewed on March 4, 1964.
- Republic Act No. 875 (Industrial Peace Act) initially permitted closed‐shop agreements.
- On June 18, 1961, Republic Act No. 3350 amended RA 875 to add a proviso that a closed‐shop agreement “shall not cover members of any religious sects which prohibit affiliation of their members in any such labor organization.”
- Victoriano, citing his sect’s prohibition of labor‐union membership, tendered his resignation from the Union in 1962 and again on September 3, 1974.
- The Union requested the Company to dismiss Victoriano for non‐membership; the Company threatened dismissal absent a satisfactory arrangement.
Procedural History
- Victoriano filed Civil Case No. 58894 in the Court of First Instance of Manila seeking an injunction against his dismissal by both the Company and the Union.
- The Union, in its answer, invoked the closed‐shop clause, challenged the constitutionality of RA 3350, and alleged lack of jurisdiction under RA 875.
- On August 26, 1965, the trial court enjoined the Company from dismissing Victoriano and ordered the Union to pay ₱500 attorney’s fees plus costs.
- The Union appealed directly to the Supreme Court on pure questions of law, assigning errors:
- The lower court failed to declare RA 3350 unconstitutional.
- The award of attorney’s fees to Victoriano was improper.
Issues Presented
- Is Republic Act No. 3350 unconstitutional for:
- Infringing freedom of association?
- Impairing the obligation of contract (closed‐shop clause)?
- Violating religious‐establishment and free‐exercise clauses?
- Requiring a religious test for civil rights?
- Breaching equal protection of laws?
- Contravening social‐justice directives?
- Was the trial court’s award of attorney’s fees to Victoriano improper under RA 875 or the Civil Code?
Appellant Union’s Contentions
- RA 3350 prohibits union membership by all members of certain sects, infringing freedom of association.
- The amendment impairs an existing, valid “union security clause” and thereby violates the co