G.R. No. L-59167 August 31, 1984
VICMICO INDUSTRIAL WORKERS ASSOCIATION (VIWA), represented by PAQUITO V. ANDO, petitioner, vs. THE HONORABLE CARMELO NORIEL, as BUREAU OF LABOR RELATIONS DIRECTOR, and the NATIONAL FEDERATION OF SUGAR WORKERS (NFSW), respondents.

FACTS

The National Federation of Sugar Workers (NFSW) filed a petition for a certification election among the rank-and-file employees of Victorias Milling Company, Inc., attaching signatures purportedly from more than 30% of the workforce. The petitioner union, Vicmico Industrial Workers Association (VIWA), moved to dismiss, alleging the signatures were forgeries, duplications, or from ineligible employees like managerial staff. The Med-Arbiter initially found the 1,323 signatures genuine and ordered an election. Upon VIWA’s motion for reconsideration, which claimed 605 members had disaffiliated from NFSW, the Med-Arbiter set the case for rehearing. Subsequently, the Med-Arbiter recalculated, finding only 686 valid signatures against a required 30% threshold of 906 from a workforce of 3,017, and thus indicated the petition lacked the required support.

ISSUE

Whether the Bureau of Labor Relations Director committed grave abuse of discretion in ordering a certification election despite questions regarding the sufficiency and authenticity of the supporting signatures and alleged mass disaffiliations.

RULING

The Supreme Court dismissed the petition, upholding the Director’s order for a certification election. The legal logic is anchored on the non-adversarial and fact-finding nature of certification proceedings. The Med-Arbiter’s initial factual finding that the 1,323 submitted signatures appeared genuine and constituted over 30% of the bargaining unit was conclusive. This finding, sustained by the Director, made the holding of a certification election mandatory under the Labor Code. The Court ruled that alleged withdrawals or retractions of support are best resolved not in pre-election litigation but through the secret ballot of the certification election itself, allowing workers to freely express their current choice. This approach aligns with the policy of ensuring the employees’ right to self-organization. The Court further noted that the disaffiliation issue was raised belatedly, casting doubt on its veracity, and emphasized that even assuming the 30% requirement was not met, the Bureau retains discretion to order an election to ascertain the employees’ true representative. The factual determinations of the labor officials are accorded respect and finality.