G.R. No. L-15416; April 28, 1960
THE UNIVERSITY OF THE PHILIPPINES AND CONCEPCION DE. ANONAS, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.

FACTS

An acting prosecutor of the Court of Industrial Relations (CIR) filed a complaint for unfair labor practice against the University of the Philippines (UP) and Concepcion Anonas, the matron of the UP Women’s South Dormitory. The complaint, initiated by a labor union and three of its members (Fabiana Borines, Epifania Abijay, and Alicia Ebalo), alleged that the petitioners discriminated against these union members by not reappointing them as helpers in connection with their demands for better working conditions. The petitioners moved to dismiss the case, arguing that the CIR lacked jurisdiction because UP is a state agency performing governmental functions and is a non-profit organization not subject to Republic Act No. 875 (the Industrial Peace Act). The CIR denied the motion to dismiss and a subsequent motion for reconsideration. The petitioners then filed this petition for certiorari with preliminary injunction before the Supreme Court.

ISSUE

1. Whether the Court of Industrial Relations has jurisdiction over a complaint for unfair labor practice filed against the University of the Philippines.
2. Whether the complaint states a valid cause of action.

RULING

The Supreme Court granted the petition, set aside the CIR orders, and dismissed the complaint.
1. On Jurisdiction: The Court held that the CIR has no jurisdiction over the complaint. The University of the Philippines, established to provide advanced instruction and professional training, performs a legitimate governmental function and is maintained by the Government. It is a non-profit institution of higher education, not an industrial or business organization operated for profit. Citing Boy Scouts of the Philippines vs. Araos and University of Santo Tomas vs. Villanueva, the Court ruled that labor legislation, including Republic Act No. 875 on unfair labor practices, applies only to employers engaged in industry, occupations, or purposes of profit and gain. It does not apply to entities organized for elevated purposes such as education.
2. On Cause of Action: The Court further held that the complaint failed to state a valid cause of action. The complaint itself alleged that the complaining union members were temporary employees whose appointments were not renewed. Following settled doctrine, a temporary employee has no fixed tenure and may be terminated at the pleasure of the appointing power without need to show cause. Therefore, their separation from service was justified.
Separate Opinion:
Justice Concepcion dissented, citing the reasons in his dissenting opinion in Boy Scouts of the Philippines vs. Araos.