G.R. No. L-35075. November 24, 1972
LAKAS NG MANGGAGAWANG PILIPINO, petitioner, vs. BENGUET CONSOLIDATED, INC., NATIONAL MINES AND ALLIED WORKERS’ UNION (NAMAWU-MIF), PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), BENGUET MINE WORKERS UNION, and HON. AMANDO C. BUGAYONG, in his capacity as Associate Judge of the Court of Industrial Relations, respondents. BENGUET CONSOLIDATED, INC. EMPLOYEES AND WORKERS UNION-PAFLU, intervenor.

FACTS

Petitioner Lakas ng Manggagawang Pilipino (LMP) filed a petition for certiorari and prohibition with preliminary injunction. LMP sought to compel its inclusion as an intervenor in a pending certification election proceeding (CIR Case No. 3586-MC) before respondent Judge Amando C. Bugayong of the Court of Industrial Relations (CIR). The petitioner alleged that it filed a motion for intervention, but the respondent Judge’s orders of April 28 and May 10, 1972, which set a consent election and formally denied the motion, disregarded LMP. Fearing the election would proceed without it, LMP came directly to the Supreme Court, which issued a temporary restraining order on May 15, 1972. Subsequently, the Benguet Consolidated, Inc. Employees and Workers Union-PAFLU was allowed to intervene in the Supreme Court proceeding.
During the pendency of the case before the Supreme Court, petitioner LMP filed a motion to dismiss its own petition. LMP stated that its ultimate objective—to be admitted as an intervenor in the CIR representation proceedings—could now be attained, as two other contending unions (NAMAWU-MIF and the Benguet Mine Workers Union) had expressed their conformity to LMP’s inclusion. The motion prayed for dismissal to allow the CIR to proceed with the certification election.

ISSUE

Whether the Supreme Court should grant the petitioner’s motion to dismiss the case, thereby allowing the certification election to proceed in the Court of Industrial Relations with the petitioner included as an intervenor.

RULING

The Supreme Court granted the petitioner’s motion to dismiss. The legal logic is anchored on the Court’s consistent policy of ensuring that the collective bargaining representative reflects the genuine choice of the workers, which is best ascertained through a properly conducted certification election. The Court noted that the only opposition to the dismissal came from the intervenor Union (BCI Employees and Workers Union-PAFLU), which raised various affirmative defenses, including claims that LMP failed to intervene timely, manifested disinterest, and had not exhausted remedies. The Court found these objections bereft of legal support.
Crucially, the Court emphasized the wide latitude of discretion vested in the Court of Industrial Relations in certification proceedings, as established in a long line of jurisprudence beginning with Lopez v. Chronicle Publication Employees Association. The CIR, being the agency on the ground, is in the best position to determine the proper conduct of such elections, including matters of intervention. The Supreme Court’s role is not to micromanage these proceedings but to ensure that the process leading to the election of a bargaining agent is fair and reflective of the workers’ will. Since the petitioner itself sought dismissal and the other major unions consented to its intervention, the path was clear for the CIR to hold an election encompassing all interested unions. The Court viewed the intervenor Union’s refusal to consent to a speedy election with suspicion, implying it might fear an unfavorable electoral outcome. Therefore, to serve the paramount interest of promptly determining the employees’ true representative, the motion to dismiss was granted.