G.R. No. 135806; August 8, 2002
Toyota Motors Philippines Corporation Labor Union, petitioner, vs. Toyota Motor Philippines Corporation Employees and Workers Union, Toyota Motor Philippines Corporation, and The Secretary of Labor and Employment, respondents.

FACTS

On April 24, 1997, respondent Toyota Motor Philippines Corp. Employees and Workers Union (TMPCEWU) filed a Petition for Certification Election to represent the rank-and-file employees (Levels 1 to 4) of the manufacturing division of Toyota Motor Philippines Corp. (TMPC). On May 13, 1997, petitioner Toyota Motor Philippines Corp. Labor Union (TMPCLU) filed a Motion to Intervene with Opposition, claiming to be the legitimate labor organization and arguing that the petition was premature due to a pending Supreme Court case involving an earlier certification election order. The Med-Arbiter provisionally dismissed TMPCEWU’s petition pending the Supreme Court’s final ruling. On June 3, 1997, the Supreme Court’s decision in G.R. No. 121084 (dated February 19, 1997) became final and executory, ruling that TMPCLU, whose membership included supervisory employees, could not attain legitimate status prior to purging itself of such members and thus lacked personality to file a certification election petition. After TMPCEWU revived its petition, TMPCLU filed a Petition-in-Intervention on October 30, 1997, alleging it now represented only rank-and-file employees and challenging TMPCEWU’s proposed bargaining unit as violating the “single employer” unit policy. The Med-Arbiter dismissed both petitions on February 24, 1998, ruling TMPCEWU’s proposed unit was improper and TMPCLU lacked legal personality because its certificate of registration was void ab initio due to its mixed membership at the time of issuance. The Secretary of Labor affirmed the dismissal, stating TMPCLU had not attained legitimate status as it needed to register anew after purging supervisory members. TMPCLU filed this petition for certiorari.

ISSUE

Whether the Secretary of Labor committed grave abuse of discretion in affirming the dismissal of TMPCLU’s Petition-in-Intervention on the ground that it lacked legal personality as a legitimate labor organization.

RULING

The Supreme Court DISMISSED the petition for lack of merit and AFFIRMED the assailed Resolution and Order of the Secretary of Labor. The Court held that the Secretary of Labor did not commit grave abuse of discretion. It ruled that TMPCLU did not possess the requisite legal personality to intervene in the certification election proceedings. Citing its final and executory decision in G.R. No. 121084, the Court reiterated that since TMPCLU’s membership list at the time of its application for registration contained names of supervisory employees, it could not, prior to purging itself of such members, attain the status of a legitimate labor organization. The Court further held that the mere issuance of a certificate of registration is not conclusive proof of legitimacy if the application was vitiated by circumstances violating the Labor Code, such as the inclusion of ineligible members. The need for TMPCLU to register anew after purging its supervisory members was imperative, as one of the registration requirements is the submission of a list of officers. Since TMPCLU had not done so, it had not yet attained legitimate status and therefore had no legal authority to oppose the certification election petition. The procedural requirements to impugn its registration were adequately complied with through the previous Supreme Court ruling.