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 its members (Fabiana Borines, Epifania Abijay, and Alicia Ebalo), alleged that the petitioners discriminated against these union members by not reappointing them in relation to 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

Whether the Court of Industrial Relations has jurisdiction over the unfair labor practice complaint filed against the University of the Philippines.

RULING

The Supreme Court GRANTED the petition. The Court held that the CIR has no jurisdiction over the complaint.
1. Lack of Jurisdiction: The University of the Philippines, established to provide advanced instruction and professional training, performs a governmental function and is a non-profit educational institution. Following the precedent set in Boy Scouts of the Philippines vs. Araos and reiterated in University of Santo Tomas vs. Villanueva, the Court ruled that labor legislation, including Republic Act No. 875 concerning unfair labor practices, applies only to industrial employment and employers engaged in industry or occupations for profit. It does not apply to non-profit entities organized for elevated purposes such as education. Therefore, the CIR had no jurisdiction to entertain the complaint against UP.
2. Failure to State a Cause of Action: The Court additionally found that the complaint failed to state a valid cause of action. The complaint itself alleged that the complaining employees were temporary workers whose appointments were not renewed. Applying settled doctrine, the Court ruled that a temporary employee has no fixed tenure and may be terminated at the pleasure of the appointing power without need to show cause. Thus, their separation was justified.
The orders of the CIR were set aside and the unfair labor practice complaint was dismissed.