G.R. No. 76189, August 8, 1991
Roberto M. Oca, Jr., et al. and Philippine Transport and General Workers Organization (PTGWO-OCA Group), petitioners, vs. Cresenciano B. Trajano, Director of the BLR-MOLE, Andres L. Dinglasan, Jr., et al. and Philippine Transport and General Workers Organization (PTGWO-Dinglasan Group) and Carlos T. Rullamas (PTGWO-III), respondents.

FACTS

The Philippine Transport and General Workers Organization (PTGWO) experienced a leadership rift. During the 11th National Convention in 1979, Andres L. Dinglasan, Jr. was elected National President and Roberto M. Oca, Jr. as National Executive Vice-President for three-year terms. In 1982, disagreements arose over the mechanics and date for the next national convention. An executive board meeting on February 26, 1982, adjourned acrimoniously. The remaining members reconvened and set the convention for April 18, 1982. Oca’s group, in a separate board meeting on March 19, 1982, scheduled their convention for April 4, 1982. Dinglasan’s group subsequently advanced their convention to the same date. Consequently, on April 4, 1982, both factions held separate conventions at different venues and elected their own sets of officers.
Dinglasan’s group filed a petition with the Bureau of Labor Relations (BLR) to declare the Oca group’s convention and election illegal. An intervening group, PTGWO-III, also sought recognition. BLR Director Cresenciano B. Trajano, in a May 15, 1986 decision, declared both conventions of doubtful validity. Finding the rift irreconcilable, he concluded PTGWO had ceased to exist and ordered the Oca and Dinglasan groups to register as separate federations (PTGWO-Oca and PTGWO-Dinglasan), while allowing PTGWO-III to register under a new name. All parties moved for reconsideration.

ISSUE

Whether the Bureau of Labor Relations Director committed grave abuse of discretion in declaring that PTGWO had ceased to exist and in ordering the rival factions to register as separate labor federations.

RULING

Yes, the Supreme Court found grave abuse of discretion and modified the BLR Director’s decision. The Court held that the Director erred in applying the doctrine of “implied trust” from property law to an intra-union conflict, which was improper. The correct basis for resolution was the PTGWO Constitution and By-Laws. Examining the provisions, the Court found both the February 26, 1982, board meeting (which Dinglasan reconvened after Oca’s group left) and the subsequent separate conventions called by each faction to be invalid for non-compliance with the union’s constitutional procedures for calling a convention.
Since both conventions were invalid, the elections held therein were likewise invalid. Consequently, under the union’s constitution, the incumbent officers (elected in 1979) were entitled to remain in office until their successors were duly elected and installed at a properly convened National Convention. The Supreme Court directed the BLR to supervise the election of PTGWO officers within sixty days from the finality of the decision. It also recognized, to avoid industrial unrest, the collective bargaining agreements entered into by both factions in good faith as valid and binding until their expiry dates. The right of any group to secede was preserved.