G.R. No. L-13365. July 31, 1963.
THE SUPERINTENDENT OF THE LA LOMA CATHOLIC CEMETERY, petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS, and the LA LOMA CATHOLIC CEMETERY FREE WORKERS (FFW), respondents.

FACTS

The La Loma Catholic Cemetery Free Workers (FFW) filed a petition with the Court of Industrial Relations (CIR) to be certified as the sole and exclusive bargaining representative for all employees and laborers of the La Loma Catholic Cemetery. The cemetery superintendent moved to dismiss the petition, arguing that the CIR lacked jurisdiction. The grounds were that the cemetery is a religious temporality of the Roman Catholic Church and a non-profit enterprise, thus not covered by Republic Act No. 875 , the Industrial Peace Act. The CIR, however, issued an order finding the Act applicable, holding the cemetery was operated “for profit or for the acquisition of wealth,” and certified the union. The CIR en banc affirmed this order.
The evidence showed the cemetery is a part of the corporation sole of the Roman Catholic Archbishop of Manila. It derives income from the sale and rental of burial lots and niches, with proceeds funding salaries, maintenance, and improvements. A chaplain is assigned, a chapel exists, and religious obligations are imposed on workers. The cemetery also buries indigents free of charge and enjoys tax exemption. The union claimed a majority membership among the cemetery’s workers.

ISSUE

Whether the Court of Industrial Relations has jurisdiction over the certification election petition, considering the nature of the La Loma Catholic Cemetery as a religious and allegedly non-profit enterprise.

RULING

The Supreme Court reversed the CIR’s resolution and order, dismissing the case for lack of jurisdiction. The legal logic is anchored on the established doctrine that the Industrial Peace Act does not apply to non-profit organizations. The Court examined the character of the La Loma Catholic Cemetery and found it to be a purely religious temporality and a non-profit enterprise. Its primary objective is religious: to provide burial according to Catholic rites in sanctified grounds. The income generated is dedicated solely to the cemetery’s maintenance and improvement, not for the benefit of private individuals. Its tax-exempt status further underscores its non-profit, religious nature.
The Court held that this case falls squarely within the precedent set in Boy Scouts of the Philippines v. Araos, which ruled that employees of non-profit organizations are not covered by the Industrial Peace Act and the CIR has no jurisdiction over certification petitions involving them. This doctrine had been consistently reiterated in subsequent cases. Consequently, despite the income from its operations, the cemetery’s essential religious and non-profit character places it outside the ambit of the labor relations statute. The CIR, therefore, acted without jurisdiction in entertaining the union’s petition and ordering the certification election.