G.R. No. L-26097 November 29, 1977
DOMINADOR ANUCENSION AND 114 OTHER IGLESIA NI CRISTO AGRICULTURAL WORKERS OF HACIENDA LUISITA, petitioners, vs. NATIONAL LABOR UNION, TARLAC DEVELOPMENT CORPORATION AND COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

Petitioners are 115 agricultural workers of Hacienda Luisita, owned by respondent Tarlac Development Corporation, and were members of the United Luisita Workers’ Union, an affiliate of respondent National Labor Union. A collective bargaining agreement (CBA) with a union shop clause was in effect, requiring all employees in the bargaining unit to remain union members as a condition of continued employment. On May 8, 1964, the petitioners, who are followers of the Iglesia ni Cristo, submitted their irrevocable resignation from the union, citing their religious beliefs which prohibit affiliation with any labor organization. The union then demanded their dismissal from the Hacienda pursuant to the CBA’s union security provision. The labor dispute was certified to the Court of Industrial Relations (CIR). The CIR declared Republic Act No. 3350 unconstitutional. This law amended the Industrial Peace Act to exclude from closed-shop agreements members of religious sects that prohibit their members from joining labor unions. The CIR consequently upheld the CBA’s union shop clause and ordered the Hacienda to dismiss the petitioners if they did not rejoin the union.

ISSUE

The core issue is whether Republic Act No. 3350 , which grants an exemption from union shop agreements to members of religious sects that forbid such affiliation, is constitutional, and consequently, whether the petitioners can be legally dismissed for resigning from the union based on their religious beliefs.

RULING

The Supreme Court reversed the CIR decision and upheld the constitutionality of Republic Act No. 3350 . The legal logic centers on the reconciliation of the constitutional guarantees of freedom of religion and the state’s policy to promote unionism. The Court ruled that the law is a valid exercise of police power, creating a reasonable classification based on substantial distinctions. The distinction rests on the unique and deeply held religious convictions of members of sects like the Iglesia ni Cristo, for whom joining a union is a sin. This classification is germane to the law’s purpose: to prevent individuals from being deprived of their right to work solely due to a conflict between their employment’s union requirements and their core religious tenets. The Court emphasized that freedom of religion is a fundamental right, and the state cannot compel a person to choose between their faith and their livelihood. The union shop clause, while generally valid, operates as a coercive measure against those with sincere religious objections. Therefore, the exemption provided by R.A. No. 3350 is a permissible accommodation to protect religious freedom. Consequently, the petitioners, covered by this exemption, cannot be dismissed for their resignation from the union. The CIR decision was vacated and the case was dismissed.