G.R. Nos. L-17207 and L-17372; October 30, 1962
U.S.T. PRESS, petitioner, vs. NATIONAL LABOR UNION, ET AL., respondents.

FACTS

The U.S.T. Press, a printing press owned and operated by the University of Santo Tomas (UST), underwent significant operational changes. In November 1955, its new director, Fr. Excelso Garcia, acting on a directive from the UST Rector, prohibited the press from accepting outside printing jobs, confining its work to university and Dominican Order projects. This policy necessitated a reduction in personnel, leading to the layoff of several employees, including Gertrudes Cortez, Artemio Juson, Eduardo Mendoza, Serafin Bañez, and Servillano Caliolio. Subsequently, in 1956, UST decided to lease the press to the Novel Publishing Company. The new management invited applications from the existing workforce, but some employees, allegedly upon their union’s instruction, did not apply and were consequently not hired.
The National Labor Union filed two unfair labor practice cases (Nos. 862-ULP and 977-ULP) with the Court of Industrial Relations (CIR) against the U.S.T. Press. The union alleged that the dismissals and the non-hiring by the new company were due to anti-union discrimination by Fr. Garcia. The U.S.T. Press moved to dismiss, arguing it lacked juridical personality and that the real party-in-interest was UST, an educational institution to which the Industrial Peace Act ( Republic Act No. 875 ) did not apply. The CIR, in a split decision, ruled against the press, finding unfair labor practice and ordering reinstatement with back wages.

ISSUE

Whether the Court of Industrial Relations had jurisdiction over the unfair labor practice cases filed against the U.S.T. Press, considering the nature of its owner, the University of Santo Tomas.

RULING

The Supreme Court reversed the CIR decision and dismissed the cases for lack of jurisdiction. The legal logic is anchored on the applicability of Republic Act No. 875 . The Court first established that the U.S.T. Press, not being a natural or juridical person, could not be sued in its own name. The real respondent was its owner, the University of Santo Tomas. The Court then applied the settled doctrine that RA 875, which governs labor relations and unfair labor practices, applies only to entities organized for profit or engaged in industry or business.
UST is an institution of learning devoted exclusively to education, not organized for profit. It declares no dividends, and its members receive no material compensation. The fact that the press occasionally accepted outside jobs was merely incidental to its primary function of serving the university. Critically, there was no evidence that profits from such work were distributed as dividends; any earnings accrued to the benefit of the non-profit educational institution. Citing precedent, including University of Santo Tomas v. Villanueva, the Court held that UST, and by extension its press, was not an industrial or business organization covered by the Industrial Peace Act. Therefore, the CIR had no jurisdiction to entertain the unfair labor practice charges. The dismissal of the employees, regardless of motive, fell outside the purview of RA 875.