GR L 13129 80; (August, 1960) (Digest)
G.R. Nos. L-13129 and L-13179-80; August 31, 1960
Benguet Consolidated Unions Council, petitioner, vs. The Court of Industrial Relations, et al., respondents.
FACTS
On May 29, 1956, the Court of Industrial Relations (CIR) issued an order directing a certification election among five designated appropriate bargaining units for the employees of Benguet Consolidated, Inc. and Balatoc Company. The Benguet-Balatoc Workers Union and the United Workers Unions were allowed to participate. This order was appealed to the Supreme Court (G.R. Nos. L-11029 and L-11065), raising the sole issue of whether there should be five bargaining units or only one, prompting the CIR to suspend the election pending the appeal’s final determination. Pending this appeal, the Benguet Consolidated Unions Council (petitioner) filed a consolidated amended petition with the CIR on June 10, 1957. It prayed to be allowed to participate in the certification election: if the Supreme Court ruled for a single bargaining unit, petitioner itself would participate; if the Court ruled for five units, petitioner would participate through its local unions (Antamok Workers Union, Acupan Mine Workers Union, Balatoc Labor Union). The CIR denied this petition on September 23, 1957, and denied reconsideration on October 18, 1957. Petitioner then filed the present certiorari petition.
ISSUE
Whether the CIR erred in denying the petition of the Benguet Consolidated Unions Council to participate in the certification election.
RULING
The Supreme Court dismissed the petition as moot and academic. The appeal in G.R. Nos. L-11029 and L-11065 from the CIR’s May 29, 1956 order was decided on May 23, 1958, affirming said order. Subsequently, the certification election was held on November 3, 1958, without petitioner’s participation. Since the relief sought—participation in that election—had already been overtaken by the holding of the election, the main issue became moot.
Furthermore, the Court found no merit in petitioner’s claim. The CIR had correctly denied participation because the nature of petitioner’s organization was unclear. It was either a mere conglomeration of unions already represented (with no showing those unions desired representation by the Council) or, as the CIR found, it was composed of employees also affiliated with the Benguet-Balatoc Workers Union—a union already authorized to participate in the election. The CIR noted petitioner failed to show it commanded the requisite 10% membership support and that the situation presented a conflict between two unions (the Council and Benguet-Balatoc Workers Union) claiming the same membership. This was deemed an internal or “jurisdictional” affair of the workers and their unions, best resolved by the workers themselves, not by the CIR. Citing a similar ruling from the U.S. National Labor Relations Board, the Court agreed that such internal union disputes should not be decided by the industrial court. The order of the CIR dated September 23, 1957 was affirmed.