G.R. No. L-21278, L-21462, L-21500 December 27, 1966
FEATI UNIVERSITY, petitioner, vs. HON. JOSE S. BAUTISTA, Presiding Judge of the Court of Industrial Relations and FEATI UNIVERSITY FACULTY CLUB-PAFLU, respondents. (Consolidated Cases)

FACTS

On January 14, 1963, the Feati University Faculty Club-PAFLU (Faculty Club), a registered labor union composed of university professors and instructors, informed Feati University (University) of its organization. On January 22, 1963, it sent a letter with twenty-six employment-related demands. The University requested time to study the demands and asked for proof of the union’s majority status. The Faculty Club rejected the extension request and, on February 1, 1963, filed a notice of strike for refusal to bargain. Conciliation failed, and a strike commenced on February 18, 1963, disrupting classes. On March 21, 1963, the President of the Philippines certified the dispute to the Court of Industrial Relations (CIR) under Section 10 of Republic Act No. 875 (Industrial Peace Act).
Three CIR cases are relevant:
1. CIR Case No. 41-IPA: The certified dispute. The University moved to dismiss, arguing the CIR lacked jurisdiction because the Industrial Peace Act did not apply to an educational institution or to professors as “independent contractors,” and the certification was invalid. On March 30, 1963, respondent Judge Jose S. Bautista denied the motion, upheld CIR jurisdiction, and ordered strikers to return to work and the University to readmit them under a status quo arrangement. The University filed a motion for reconsideration en banc. Subsequently, the Faculty Club filed a petition for contempt, alleging the University refused readmission. On April 6, 1963, the Judge issued an order warning replacements not to disrupt the return-to-work order.
2. CIR Case No. 1183-MC: A petition for certification election filed by the Faculty Club. The University moved to dismiss on similar jurisdictional grounds. Before resolution, the Faculty Club moved to withdraw the petition, arguing the issues were absorbed by the certified Case No. 41-IPA. The University opposed. On April 6, 1963, Judge Baltazar Villanueva granted the withdrawal.
3. CIR Case No. V-30: A complaint for indirect contempt filed against the University’s President and counsel for alleged violations of CIR orders (details truncated in provided text).
The University filed three separate petitions/appeals to the Supreme Court, which were consolidated.
* G.R. No. L-21278: A petition for certiorari and prohibition seeking to annul the CIR’s proceedings and orders in the three cases and to dismiss them.
* G.R. No. L-21462: An appeal from the CIR order granting the withdrawal of the certification election petition (Case No. 1183-MC).
* G.R. No. L-21500: An appeal from the CIR order of March 30, 1963 (in Case No. 41-IPA) and the en banc resolution denying its reconsideration.

ISSUE

The primary issue, common to the consolidated cases, is whether the Court of Industrial Relations has jurisdiction over the labor dispute between Feati University and the Feati University Faculty Club-PAFLU. Specifically, whether the Industrial Peace Act ( R.A. No. 875 ) applies to an educational institution and to its faculty members, thereby granting the CIR authority to act on the certified dispute and related incidents.

RULING

The Supreme Court ruled in the affirmative, upholding the jurisdiction of the Court of Industrial Relations.
1. Applicability of the Industrial Peace Act to Educational Institutions: The Court held that the Industrial Peace Act applies to all branches of human activity where the relationship of employer and employee exists, whether for profit or not. The law does not exclude educational institutions. The University, as an employer, and its faculty members, as employees, fall within the Act’s coverage.
2. Status of Faculty Members as Employees: The Court rejected the University’s claim that professors are “independent contractors.” It ruled that faculty members are employees of the university. They perform work under the employer’s control, with the employer providing the tools, place, and manner of work (the academic environment). They are compensated for their services, which are integral to the institution’s purpose.
3. Validity of the Presidential Certification: The Court held the presidential certification of the dispute to the CIR was valid. The certification is an executive function, and the CIR properly acquired jurisdiction upon such certification. The existence of a labor dispute that threatened national interest was sufficient basis for the certification.
4. Disposition of the Consolidated Cases:
* G.R. No. L-21278: The petition for certiorari and prohibition was dismissed. The writs were denied and the preliminary injunction dissolved. The CIR’s assumption of jurisdiction and its orders were upheld.
* G.R. No. L-21462: The appealed order granting the withdrawal of the certification election petition was affirmed. The issues in that case were absorbed by the main certified case (41-IPA).
* G.R. No. L-21500: The appealed order of March 30, 1963, and the en banc resolution denying reconsideration were affirmed.
Costs were awarded against Feati University.