G.R. No. L-12919. October 30, 1962. UNIVERSITY OF SANTO TOMAS HOSPITAL, petitioner, vs. U.S.T. HOSPITAL EMPLOYEES ASSOCIATION (NLU), ET AL., respondents.
FACTS

The Court of Industrial Relations (CIR) charged the University of Santo Tomas Hospital with unfair labor practice under Section 4(a) of Republic Act No. 875 , the Industrial Peace Act, for alleged acts against the union president, Felipe L. Torrecampo. The hospital filed a motion to dismiss, contending that the CIR lacked jurisdiction and that R.A. 875 did not apply to its employment relations. The CIR, through Judge Emiliano C. Tabigne, denied the motion, holding that R.A. 875 did not exclude non-industrial entities like charitable or educational institutions from its coverage. This ruling was affirmed by the CIR en banc, prompting the hospital’s appeal to the Supreme Court.

ISSUE

The core issue is whether Republic Act No. 875 , governing unfair labor practices and labor disputes, applies to the employment relationship between the University of Santo Tomas Hospital and its employees, thereby conferring jurisdiction on the Court of Industrial Relations.

RULING

The Supreme Court reversed the CIR’s decision and dismissed the complaint, holding that R.A. 875 does not apply to the petitioner. The legal logic is anchored on the legislative intent and judicial construction of the Industrial Peace Act. The Court, citing its controlling precedent in Boy Scouts of the Philippines v. Araos, definitively ruled that R.A. 875 was intended by Congress to apply only to industrial employment—that is, to govern relations between employers engaged in industry, trade, or occupation for purposes of profit or gain and their industrial employees. The Act’s provisions on unfair labor practices and labor disputes were not meant to extend to organizations operated not for profit but exclusively for social service, education, or medical service.
Applying this doctrine, the Court found the University of Santo Tomas Hospital to be an institution owned and operated by the University of Santo Tomas, which is maintained not for profit but for educational purposes. Consequently, the employment relationship between the hospital and its staff falls outside the purview of R.A. 875. This ruling was consistently reiterated in subsequent cases, including University of San Agustin v. Court of Industrial Relations and The Elks Club v. The United Laborers & Employees of the Elks Club. Therefore, the CIR had no jurisdiction to entertain the unfair labor practice complaint, as the governing law was inapplicable to the non-profit, educational character of the employer.