G.R. No. L-25943. January 30, 1971.
MANILA CORDAGE COMPANY, petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS AND MANILA CORDAGE WORKERS UNION-PAFLU, respondents.

FACTS

The Manila Cordage Workers Union-PAFLU declared a strike against Manila Cordage Company on May 16, 1965. On October 14, 1965, the company and union officers, led by Juanito Tabuyan, signed a return-to-work agreement, ending the strike and providing for the staggered reinstatement of workers. This agreement was implemented. Subsequently, on October 22, 1965, the President certified the labor dispute to the Court of Industrial Relations (CIR). The company moved to dismiss or suspend the CIR proceedings, arguing the certification was baseless due to the existing return-to-work agreement and a new collective bargaining agreement signed on December 23, 1965. The CIR denied the motions, prompting this petition for review.

ISSUE

The primary issue is whether the CIR erred in not dismissing or suspending the proceedings despite the existence of the return-to-work and collective bargaining agreements, which petitioner argued negated the basis for the presidential certification and the CIR’s compulsory arbitration.

RULING

The Supreme Court affirmed the CIR’s order for workers to return to work but remanded the case for further proceedings. The Court held that a presidential certification, once issued, confers jurisdiction upon the CIR, and the judiciary cannot review the factual basis for the President’s discretion. The existence of a return-to-work agreement does not automatically oust the CIR of jurisdiction, as such agreements do not necessarily resolve all underlying disputes, especially concerning representation and the validity of subsequent collective bargaining agreements.
The legal logic centers on the nature of a certified dispute. The Court ruled that the certification empowers the CIR to assume jurisdiction and compel arbitration to ensure industrial peace, which remains paramount. The subsequent collective bargaining agreement, signed by specific union officers, was contested by a faction of the union. This raised a pivotal factual issue of due representation—whether the signatory officers truly represented the union majority. Since the CIR failed to make a finding on this critical point, the Supreme Court could not definitively rule on the agreement’s effect on the certified case. Therefore, the case was returned to the CIR to first determine the legitimacy of the union’s representation in the December 1965 agreement before proceeding to resolve the rights of the parties under the presidential certification.