GR 75724; (May, 1991) (Digest)
G.R. No. 75724 ; May 6, 1991
WESTERN AGUSAN WORKERS UNION-LOCAL 101 OF THE UNITED LUMBER AND GENERAL WORKERS OF THE PHILIPPINES (WAWU-ULGWP LOCAL 101), petitioner, vs. THE HONORABLE CRESENCIANO B. TRAJANO, in his capacity as Director of the Bureau of Labor Relations, Ministry of Labor and Employment, PHILIPPINE TRANSPORT AND GENERAL WORKERS’ ORGANIZATION (PTGWO), and WESTERN AGUSAN WORKERS UNION (WAWU), respondents.
FACTS
The case involves a petition for certification election filed by the Philippine Transport and General Workers’ Organization (PTGWO) among the rank-and-file employees of Nasipit Lumber Company (NALCO). The incumbent bargaining agent was petitioner WAWU-ULGWP Local 101, a local chapter of the national federation ULGWP. During the freedom period before the expiration of their collective bargaining agreement (CBA), a group within the local union passed a resolution to disaffiliate from ULGWP, forming respondent WAWU (KMU-WAWU). The Med-Arbiter ordered a certification election, declared the disaffiliation valid, and included PTGWO, WAWU (the disaffiliated group), and “No Union” as choices on the ballot, excluding the original petitioner union, WAWU-ULGWP Local 101. The Bureau of Labor Relations (BLR) affirmed this order.
ISSUE
The primary issue is whether the Med-Arbiter and the BLR Director committed grave abuse of discretion in ordering a certification election and in ruling on the validity of the local union’s disaffiliation from its mother federation.
RULING
The Supreme Court dismissed the petition as moot and academic, affirming the BLR’s decision. The legal logic centers on the primacy of certification elections as the democratic mechanism to ascertain the true representative of employees. The Court held that any doubt regarding the support for a petitioning union or the legitimacy of a disaffiliation move is best resolved through a certification election itself, where workers can freely express their choice by secret ballot. The fact of disaffiliation, which was demonstrated to have occurred within the legally prescribed freedom period, is itself a compelling reason to hold an election to determine the new bargaining agent.
The Court further ruled that challenges to the authenticity of support signatures for a certification petition do not bar the holding of an election. Even assuming the evidence of support is insufficient, it does not militate against conducting an election, as the results will ultimately reveal the employees’ will. The subsequent execution of a new CBA between NALCO and the disaffiliated WAWU during the pendency of the case rendered other issues, such as the collection of union dues, moot. The Court emphasized that a certification election is the most expeditious means to settle representation disputes, especially following a disaffiliation.