G.R. No. 51337 . March 22, 1984.
UNITED CMC TEXTILE WORKERS UNION, Petitioner, vs. BUREAU OF LABOR RELATIONS, HON. CARMELO NORIEL, PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS, (JULY CONVENTION), Respondents.

FACTS

Petitioner United CMC Textile Workers Union is the incumbent collective bargaining representative for rank-and-file workers of Central Textile Mills, Inc. (CENTEX). On August 31, 1978, petitioner filed an unfair labor practice (ULP) case against CENTEX and respondent Philippine Association of Free Labor Unions (PAFLU), alleging that CENTEX assisted PAFLU in organizing by allowing solicitation of members from petitioner’s union during company time and on company premises, thereby charging PAFLU as a company-dominated union. While this ULP case was pending, PAFLU filed a Petition for Certification Election on September 5, 1978, seeking to represent the same workers. Petitioner intervened and moved to dismiss the certification petition, citing the prejudicial nature of the pending ULP case. Separately, a deadlock in collective bargaining negotiations between petitioner and CENTEX led to the Labor Minister assuming jurisdiction and later directing the parties to execute a new collective bargaining agreement.

ISSUE

The primary issue is whether the pendency of an unfair labor practice case alleging that a union seeking certification is company-dominated constitutes a prejudicial question that bars the holding of a certification election.

RULING

The Supreme Court ruled in the affirmative, reversing the resolutions of the Bureau of Labor Relations. The pendency of a formal charge of company domination is a prejudicial question that must be resolved before a certification election can proceed. The legal logic is grounded in the fundamental principle that the integrity of the collective bargaining process requires that the participating union be a legitimate and independent representative of the workers. If a union is company-dominated, the votes of its members in an election would not be free, as they could be unduly influenced by management. This would frustrate the statutory scheme of genuine bargaining, effectively allowing employer imposition.
The Court emphasized that the ULP case was filed in good faith prior to the certification petition and was known to the labor officials. Established jurisprudence mandates the suspension of certification proceedings until such a charge is resolved to ensure the election reflects the workers’ true will. Consequently, the Bureau of Labor Relations committed grave abuse of discretion in ordering an election while the ULP case remained pending. This ruling on the prejudicial question made it unnecessary to address the other issues regarding the bargaining deadlock and the 30% signature requirement. The Temporary Restraining Order was made permanent pending resolution of the ULP case.