G.R. No. L-20432, October 30, 1967
JOSE MANALANG, ET AL., petitioners, vs. ARTEX DEVELOPMENT CO., INC., ET AL., respondents.

FACTS

Petitioners Jose Manalang, Marcelino de Leon, and Bernardo Lactao were employees of respondent Artex Development Co., Inc. (the Company) and members of the respondent Bagong Buhay Labor Union (BBLU). The BBLU had a collective bargaining agreement (CBA) with the Company, effective March 4, 1960, containing a closed-shop provision requiring all employees to be members in good standing of the BBLU as a condition of employment. In April 1960, the petitioners organized a new union, the Artex Free Workers (FFW), and affiliated it with the Federation of Free Workers, without first resigning from the BBLU. The BBLU’s board investigated the petitioners, found them guilty of disloyalty, and expelled them from the union on June 1, 1960. Pursuant to the closed-shop clause in the CBA, the BBLU passed a resolution requesting the Company to dismiss the petitioners due to their loss of good standing. The Company complied, dismissing the petitioners on June 3, 1960. The petitioners filed an unfair labor practice charge against the Company and the BBLU with the Court of Industrial Relations (CIR), alleging their dismissal was due to their concerted activities in forming a new union. The CIR’s Presiding Judge ordered their reinstatement with back wages and their readmission to the BBLU, finding the petitioners were unaware of the CBA’s closed-shop provision and that their dismissal was discriminatory. The CIR en banc reversed this decision, holding that the Company merely complied with the CBA and that any liability lay with the BBLU, not the Company. The petitioners then filed this certiorari petition.

ISSUE

Whether the dismissal of the petitioners pursuant to the closed-shop provision of the collective bargaining agreement constitutes an unfair labor practice, given their claim that they were unaware of the agreement’s contents.

RULING

The Supreme Court affirmed the CIR en banc resolution, ruling that no unfair labor practice was committed by either the Company or the BBLU. The Court found that the petitioners, as members of the BBLU, were bound by the CBA entered into by their union as their agent, regardless of their personal knowledge or approval of its terms. The Court inferred from the circumstances that the petitioners were aware of the CBA’s provisions, including the closed-shop clause, noting they had worked at the Company since December 1959, were influential enough to organize a new union, and likely knew of the prior CBA and ongoing negotiations. Their claim of ignorance was deemed an afterthought, as they did not disavow knowledge prior to dismissal. The Court upheld the validity of the closed-shop provision as a legitimate union security measure, consistent with prior jurisprudence. Since the petitioners violated the CBA by forming a rival union while still BBLU members, their expulsion and subsequent dismissal were valid under the agreement. The Company’s compliance with the BBLU’s request for dismissal was a contractual obligation, not an unfair labor practice.