G.R. No. L-48007 December 15, 1982
PLUM FEDERATION OF INDUSTRIAL AND AGRARIAN WORKERS, petitioner, vs. DIRECTOR CARMELO C. NORIEL, of the Bureau of Labor Relations; MANILA JOCKEY CLUB RACE DAY OPERATION EMPLOYEES LABOR UNION-PTGWO and MANILA JOCKEY CLUB, INC., respondents.

FACTS

Petitioner PLUM Federation filed a petition on May 5, 1976, seeking certification as the sole and exclusive bargaining agent for the rank-and-file workers of Manila Jockey Club, Inc., following the expiration of the existing collective bargaining agreement. Respondent union MJCRDOELU-PTGWO, the incumbent bargaining agent, moved to intervene and oppose the petition, invoking its status and ongoing negotiations for a modified agreement. It later filed a supplemental motion to dismiss, citing the “No Union Raiding Clause” of the Code of Ethics of the Trade Union Congress of the Philippines (TUCP), to which both unions belonged, and questioned PLUM’s compliance with the 30% subscription requirement.
The Bureau of Labor Relations (BLR) forwarded the case records to the TUCP President for resolution. The TUCP’s National Executive Board subsequently decided to declare the respondent union as the sole bargaining agent and dismiss PLUM’s petition. The BLR, through a Med-Arbiter, dismissed PLUM’s petition based solely on this TUCP decision. PLUM’s appeal to the BLR Director was denied, with the resolution emphasizing the need to respect the TUCP’s internal decision to preserve labor unity and industrial peace.

ISSUE

Whether the Bureau of Labor Relations committed grave abuse of discretion in dismissing the petition for certification election based on a decision of the TUCP, a private entity, thereby allegedly impairing the employees’ constitutional right to choose their bargaining representative.

RULING

Yes. The Supreme Court nullified the BLR’s orders and resolutions. The legal logic is clear: the authority to order a certification election is a statutory function of the BLR under the Labor Code, designed to ascertain the true will of the employees through a secret ballot. This function cannot be abdicated or delegated to a private organization like the TUCP. While the TUCP’s internal rules, such as its Code of Ethics, bind its member unions inter se, these private agreements cannot supersede the mandatory legal process for determining representation.
The Court emphasized that certification election is the fundamental democratic mechanism to protect the employees’ freedom of association and their right to bargain collectively, as guaranteed by the Constitution. By relying on the TUCP’s decision instead of exercising its own statutory mandate to conduct an election, the BLR effectively impaired this freedom. Doubts regarding the required 30% support or the existence of a collective bargaining agreement are best resolved by holding a certification election, not by deferring to a private entity’s internal resolution. The Court ordered the immediate holding of a certification election to promptly determine the employees’ legitimate representative.