G.R. No. L-25246 September 12, 1974
BENJAMIN VICTORIANO, plaintiff-appellee, vs. ELIZALDE ROPE WORKERS’ UNION and ELIZALDE ROPE FACTORY, INC., defendants, ELIZALDE ROPE WORKERS’ UNION, defendant-appellant.

FACTS

Benjamin Victoriano, a member of the Iglesia ni Cristo, was an employee of Elizalde Rope Factory, Inc. and a member of the Elizalde Rope Workers’ Union. The Union had a collective bargaining agreement (CBA) with the Company containing a closed shop provision, making union membership a condition of employment. In 1962, Victoriano presented his resignation from the Union, citing his religious beliefs which prohibited affiliation with any labor organization, a right recognized under the newly enacted Republic Act No. 3350 . This law amended the Industrial Peace Act ( Republic Act No. 875 ) to exempt members of such religious sects from closed shop agreements.
The Union demanded the Company dismiss Victoriano for resigning his membership. Faced with impending termination, Victoriano filed an action for injunction with the Court of First Instance of Manila to prevent his dismissal. The trial court ruled in his favor, enjoining the Company from dismissing him and ordering the Union to pay attorney’s fees. The Union appealed directly to the Supreme Court, raising purely legal questions, primarily challenging the constitutionality of Republic Act No. 3350 .

ISSUE

The core issue is whether Republic Act No. 3350 , which exempts members of religious sects prohibiting labor union affiliation from closed shop agreements, is constitutional.

RULING

The Supreme Court upheld the constitutionality of Republic Act No. 3350 and affirmed the trial court’s decision. The Court systematically rejected all constitutional challenges posed by the Union. The law does not infringe on the right to form associations but merely prevents the compulsory affiliation of those whose religious beliefs forbid it, thereby protecting the more fundamental right to religious freedom. It does not impair the obligation of contracts, as the police power of the state allows for regulations affecting existing contracts for the public good, such as protecting religious liberty.
The Court found no unlawful discrimination, as the classification between members of qualifying religious sects and other workers is based on substantial distinctions (religious belief) and is germane to the purpose of the law, which is to accommodate religious practice. The Act does not impose a religious test for the exercise of a civil right; rather, it removes a previous barrier (compulsory unionism) that forced individuals to choose between their faith and their livelihood. Furthermore, the law aligns with the constitutional mandate to promote social justice by protecting the worker’s welfare, including his spiritual beliefs. The exemption is a valid exercise of legislative power designed to prevent a clash between the demands of union security and the tenets of religious faith.