GR 162103; (June, 2009) (Digest)
March 16, 2026GR 162538; (June, 2009) (Digest)
March 16, 2026G.R. No. L-28805 August 10, 1981
NATIONAL POWER CORPORATION SUPERVISORS’ UNION, petitioner, vs. NATIONAL POWER CORPORATION, NATIONAL POWER CORPORATION EMPLOYEES & WORKERS ASSOCIATION, ATTY. SIMPLICIO S. BALCOS and HONORABLE JUDGE ARSENIO MARTINEZ as Presiding Judge of the Court of Industrial Relations, respondents.
FACTS
A labor dispute between the National Power Corporation (NPC) and the NPC Employees and Workers Association (NPCEWA), a union of rank-and-file employees, was certified to the Court of Industrial Relations (CIR). The dispute involved demands for salary adjustments. The National Power Corporation Supervisors’ Union (Supervisors’ Union), a separate union representing supervisory personnel, filed a Motion to Intervene, citing its legal interest and existing collective bargaining agreement. The CIR did not act on this motion. Subsequently, NPC and the NPCEWA submitted a Supplementary Agreement granting salary increases to rank-and-file employees, which the CIR approved as its award on January 8, 1968.
Respondent Judge Arsenio Martinez then issued an Order dated February 6, 1968, directing NPC to deduct 20% of the awarded salary increases as attorney’s fees for NPCEWA’s counsel, Atty. Simplicio Balcos, from “all NPC employees and/or workers.” NPC sought clarification on whether this included supervisors. In an Order dated February 28, 1968, respondent Judge clarified that the deduction applied to all employees, including supervisors, as they allegedly benefited from the award. The Supervisors’ Union, whose motion for intervention remained unresolved, filed an urgent motion to set aside the orders as they pertained to supervisors, but this too was not acted upon.
ISSUE
Whether the CIR could legally compel supervisors, represented by a separate union, to pay attorney’s fees to the counsel of the rank-and-file union based on an award from which they derived no direct benefit and in a proceeding where they were denied intervention.
RULING
The Supreme Court ruled in the negative, granting the petition for certiorari. The legal logic is anchored on the absence of an attorney-client relationship and a denial of due process. First, the Supplementary Agreement and the January 8, 1968 award were explicitly between NPC and the NPCEWA alone. The CIR’s own order approving it contained a proviso that it would not affect the existing collective bargaining agreement of the Supervisors’ Union. Therefore, the supervisors’ subsequent salary adjustments were not a result of this award but were implemented pursuant to their own separate CBA. Since Atty. Balcos rendered no service to the Supervisors’ Union, there was no basis to charge its members attorney’s fees.
Second, the CIR committed a grave abuse of discretion by issuing the assailed orders without first resolving the Supervisors’ Union’s pending Motion to Intervene. Procedural due process requires that a party be heard before a judgment affecting its rights is rendered. By imposing a financial obligation on the supervisors without granting them an opportunity to be heard on the matter, the CIR deprived them of this fundamental right. Consequently, the Orders dated February 6 and 28, 1968, were set aside insofar as they pertained to the petitioner Supervisors’ Union.

