GR L 2771; (April, 1950) (Digest)
G.R. No. L-2771; April 29, 1950
ALFONSO UMALI, for and in behalf of 201 members of the Independent Employees Union, petitioner, vs. PRIMITIVO LOVINA, in his capacity as Secretary of Labor of the Philippines, respondent.
FACTS
The Independent Employees Union, composed of 201 employees of the Jai Alai Corporation, filed an application for registration as a legitimate labor union under Commonwealth Act No. 213. The Secretary of Labor refused to register the union, citing a policy of allowing only one union per company, especially if the unions are of the same nature. The Secretary also claimed the investigation was incomplete due to the union’s failure to submit a filled-out questionnaire. Despite the Secretary’s prior written commitment to register the union if the existing Jai Alaistas Union of Employees failed to hold an election by a specified date—a condition which was not met—registration was still denied.
ISSUE
Whether the Secretary of Labor may lawfully refuse to register a labor union based on a “one union per company” policy and for failure to submit a questionnaire, thereby justifying the issuance of a writ of mandamus.
RULING
No. The Supreme Court granted the writ of mandamus, compelling the Secretary of Labor to register the Independent Employees Union. The Court held that:
1. The Secretary’s “one union per company” policy contravenes Commonwealth Act No. 213, which only allows refusal of registration if the union’s objectives are to undermine the government or violate Philippine laws.
2. The investigation required by law was deemed completed, as inferred from the Secretary’s official correspondence indicating he had already assessed the union’s lawful purposes. The union’s failure to answer a questionnaire does not excuse the Secretary from performing his statutory duty to complete the investigation within a reasonable time.
3. The Secretary has a ministerial duty to register a union that complies with the law. His refusal, based on an extra-legal policy and an incomplete investigation due to a mere questionnaire, constituted neglect of duty, unlawfully excluding the union from its right to registration.
The Court ordered the registration of the union upon payment of the required fee.
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