G.R. No. L-28223 August 30, 1968
MECHANICAL DEPARTMENT LABOR UNION SA PHILIPPINE NATIONAL RAILWAYS, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and SAMAHAN NG MGA MANGGAGAWA SA CALOOCAN SHOPS, respondents.

FACTS

The case originated from a petition filed by the respondent Samahan ng mga Manggagawa sa Caloocan Shops (Samahan) with the Court of Industrial Relations (CIR). The Samahan sought a certification election to determine the proper collective bargaining agency for the workers at the Caloocan Shops of the Philippine National Railways (PNR), noting the existence of three unions there. The petitioner, Mechanical Department Labor Union sa PNR, opposed the petition. It argued that it had been previously certified as the sole bargaining agent for all employees of the PNR’s Mechanical Department, had negotiated collective bargaining agreements in 1961 and 1963, and that a renewed agreement was pending signature. It contended the Caloocan Shops were not a separate unit from the Mechanical Department and that the Samahan, a newly formed union, aimed to disturb smooth labor relations. The CIR trial judge found that the Caloocan Shops, with about 360 workers, were part of the Mechanical Department but that its workers had a community of interest, working in one location under the same conditions and performing major repairs using heavy machinery, unlike workers in Manila sheds who performed minor repairs. The judge also reviewed the collective bargaining history of PNR, which showed a pattern of establishing new, separate bargaining units from existing ones based on plebiscites. Applying the “Globe doctrine,” the CIR ordered a plebiscite to let the Caloocan Shops workers decide if they wanted to separate and be represented by the Samahan. The CIR en banc sustained this order, prompting the Mechanical Department Labor Union to appeal to the Supreme Court.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in ordering a plebiscite to determine if the workers of the Caloocan Shops should be separated from the Mechanical Department bargaining unit to form their own unit represented by the Samahan.

RULING

The Supreme Court affirmed the order of the Court of Industrial Relations. It held that no grave abuse of discretion was committed. The Court emphasized that Republic Act No. 875 primarily entrusted such policy matters to the CIR, whose factual findings and exercise of discretion are accorded respect. The CIR correctly found a basis for a separate unit, noting the Caloocan Shops workers’ distinct community of interest, working conditions, and the special skills required for major repairs using heavy equipment, setting them apart from other Mechanical Department workers. The application of the “Globe doctrine,” which considers the employees’ will in determining representation, was appropriate. The Court also noted that the existing collective bargaining agreements negotiated by the petitioner union had been in existence for over two years and thus did not bar the determination of a new representative. The pending issue regarding the supervisory status of some Samahan members was not a legal obstacle to holding the plebiscite. The validity of the agreement negotiated by the petitioner union during the pendency of the case was a matter for the CIR to decide first.