G.R. No. 83190 August 4, 1992
CEBU SEAMEN’S ASSOCIATION, INC., petitioner, vs. HON. PURA FERRER-CALLEJA, SEAMEN’S ASSOCIATION OF THE PHILS./DOMINICA C. NACUA, respondent.

FACTS

On October 23, 1950, a group of deck officers and marine engineers organized and registered a non-stock corporation with the Securities and Exchange Commission (SEC) known as Cebu Seamen’s Association, Inc. (CSAI). The same group registered the association with the Bureau of Labor Relations (BLR) as a labor union known as the Seamen’s Association of the Philippines, Incorporated (SAPI) on June 23, 1969. SAPI had an existing collective bargaining agreement (CBA) with Aboitiz Shipping Corporation. In February 1987, a group headed by Manuel Gabayoyo, claiming to be the new set of officers elected on January 20, 1987 under SEC supervision, demanded the remittance of checked-off union dues from the company. On May 26, 1987, another group headed by Dominica C. Nacua, claiming to be the duly elected officers from an election held on December 20, 1986, filed a complaint against CSAI (represented by Gabayoyo) seeking to secure the CBA and an order directing Aboitiz to remit the checked-off dues. CSAI argued that the union and CSAI were the same, that Nacua and another representative had been expelled as members/officers in November 1984, and that its set of officers had the lawful right to the funds per an SEC resolution. The Med-Arbiter ruled in favor of the Nacua group, a decision affirmed by the Bureau of Labor Relations. Hence, this petition.

ISSUE

1. Whether the Med-Arbiter of Region VII has jurisdiction over the case.
2. Whether the complainant-appellee Seamen’s Association of the Philippines was registered as a labor federation with the Bureau of Labor Relations.
3. Whether Dominica C. Nacua and Prospero Paradilla have the personality to represent the complainant-appellee, considering their alleged expulsion from the association.

RULING

The Supreme Court dismissed the petition and affirmed the resolution of the Bureau of Labor Relations.
1. The controversy is an intra-union dispute involving claims to rights under the Labor Code. Article 226 of the Labor Code vests the Bureau of Labor Relations and Labor Relations Divisions with original and exclusive authority over inter-union and intra-union disputes. Thus, the Med-Arbiter and the Director correctly assumed jurisdiction.
2. The determinative issue was which set of officers was entitled to the collection and custody of the union dues. The Court held that SAPI, the legitimate labor union registered with the BLR, is not the same association as CSAI, the corporation registered with the SEC, insofar as rights under the Labor Code are concerned. The registration with the BLR made SAPI a legitimate labor organization with rights and privileges under the Labor Code. CSAI was found to be already inoperational, with the SEC having ordered it to show cause why its registration should not be revoked for continuous inoperation.
3. The expulsion of Nacua from the corporation did not affect her membership in the labor union. The group headed by Gabayoyo was elected under SEC supervision as officers of the corporation, not the union. Their proceedings and actions could not affect the union and its members. The Nacua group was the lawful set of officers of SAPI, as evidenced by the list of new officers submitted to the BLR in compliance with the Labor Code. Therefore, the Nacua group was entitled to the release and custody of the union dues and agency fees.