G.R. No. L-20792; May 31, 1965
ELIZALDE and CO., INC., doing business under the name “HACIENDA VALENCIA,” petitioner, vs. ALLIED WORKERS’ ASSOCIATION OF THE PHILIPPINES, Bais Chapter, Agricultural Section (AWA) and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The Allied Workers’ Association of the Philippines, Bais Chapter, Agricultural Section, a duly registered labor organization, filed a petition with the Court of Industrial Relations (CIR) for certification as the sole and exclusive bargaining representative of all employees of the “Hacienda Valencia,” owned and operated by petitioner Elizalde & Co., Inc. The petitioner moved to dismiss the petition, claiming that the workers involved were all agricultural workers in a sugar cane hacienda. It argued that, pursuant to the ruling in Santos vs. C.I.R., controversies between capital and labor in agricultural lands are within the exclusive jurisdiction of the Court of Agrarian Relations (CAR) and not the CIR. The CIR hearing judge granted the motion to dismiss. However, upon appeal to the CIR en banc, the court, by majority vote, reversed the dismissal. It asserted that it had exclusive jurisdiction over all cases pertaining to the union rights of employees, including agricultural workers, by virtue of Section 27 of Republic Act 2263. Elizalde & Co., Inc. then filed this petition for certiorari to review the CIR’s resolution asserting jurisdiction.

ISSUE

Whether the Court of Industrial Relations has jurisdiction over a petition for certification election filed by a union composed of agricultural workers in a sugar cane hacienda.

RULING

No. The Supreme Court reversed the resolution of the Court of Industrial Relations. The Court held that disputes involving agricultural laborers, including matters related to their union rights and representation, fall within the exclusive jurisdiction of the Court of Agrarian Relations. This ruling is based on several precedents. In Victorias Milling Co. vs. C.I.R., it was held that agricultural laborers working in sugar cane haciendas are under the CAR’s jurisdiction, even for unfair labor practice charges. Similar rulings were made in Hacienda Esperanza vs. C.I.R. and Camus vs. Court of Agrarian Relations. The rationale, as established in Santos vs. C.I.R., is that an agricultural laborer does not fall within the definition of “employee” under the Industrial Peace Act (Republic Act 875) and that any matter pertaining to the relationship between those who work on the land and landholders comes under the Agricultural Tenancy Act and the exclusive jurisdiction of the CAR. The CAR, created by Republic Act 1267, has broad jurisdiction to settle all disputes involving relationships in the cultivation of agricultural land. The rights of agricultural workers to form unions under Section 27 of Republic Act 2263 (an amendment to the Tenancy Act) are enforceable by the CAR, with violations punishable under the Tenancy Act’s penal provisions or the CAR’s contempt powers. The reference to the “sugar industry” in Republic Act 809 does not convert agricultural laborers into industrial employees. The petition for certification was ordered dismissed without prejudice to seeking relief in the proper courts.