GR 116172; (October, 1996) (Digest)
G.R. No. 116172 October 10, 1996
San Miguel Foods, Inc. Cebu B-Meg Feed Plant, petitioner, vs. Hon. Bienvenido E. Laguesma, Undersecretary of DOLE and Ilaw at Buklod ng Manggagawa (IBM), respondents.
FACTS
Ilaw at Buklod ng Manggagawa (IBM), a legitimate labor federation, filed a petition for certification election among the monthly-paid employees of San Miguel Foods, Inc. (SMFI). An earlier, identical petition by IBM had been denied due to its failure to comply with certain mandatory requirements. After rectifying these deficiencies, IBM filed a second petition. SMFI moved to dismiss, arguing the second petition was barred by the pendency of the first and that IBM’s local chapter lacked legal personality because it did not possess a separate Certificate of Registration from the Bureau of Labor Relations (BLR). The Med-Arbiter granted the petition and ordered a certification election. This was affirmed by the DOLE Undersecretary, prompting SMFI to file the present petition for certiorari.
ISSUE
Whether a local chapter of a registered labor federation must secure a separate Certificate of Registration from the BLR to acquire legal personality and file a petition for certification election.
RULING
The Supreme Court denied the petition, affirming the orders for a certification election. The legal logic is anchored on the distinct nature of a local chapter created under a federation. A local or chapter does not need a separate BLR registration to acquire legal personality. Its legitimacy is derived from its federation, which is already duly registered. The federation’s certificate of registration, along with the chapter’s charter certificate and constitution and bylaws, sufficiently confers legal status upon the chapter. This principle is rooted in the policy of simplifying union registration to encourage labor organization. The Court emphasized that the certification election is the sole democratic means to ascertain the employees’ choice of bargaining representative. SMFI’s objections were deemed mere technicalities that subvert this fundamental right. The denial of the first petition did not bar the second, as the defects were cured, making the second petition a valid, separate initiative.