GR L 48931; (July, 1979) (Digest)
G.R. No. L-48931. July 16, 1979.
Ilaw at Buklod ng Manggagawa (IBM), petitioner, vs. Director of Labor Relations, Trade Union Congress of the Philippines, General Milling Corporation, and Associated Labor Unions, respondents.
FACTS
On June 24, 1976, petitioner Ilaw at Buklod ng Manggagawa (IBM) filed a petition for certification election among the rank-and-file employees of General Milling Corporation. The med-arbiter granted the petition. Respondent Associated Labor Unions (ALU) appealed this order to the Director of Labor Relations. Instead of resolving the appeal, the Director referred the entire case record to the Trade Union Congress of the Philippines (TUCP) based on an alleged arrangement for the federation to settle disputes involving its member-unions under its Code of Ethics. The TUCP, whose president was also the president of ALU, took no action on the case for over twenty months.
By September 1978, with the appeal still undecided, IBM filed this petition for mandamus to compel the Director to decide the case or to order the TUCP to return the records. The Director manifested willingness to decide the appeal if the records were returned. General Milling Corporation revealed it had a registered collective bargaining agreement with ALU set to expire in August 1979, a renewal of the earlier agreement that had prompted IBM’s 1976 petition.
ISSUE
Whether the Director of Labor Relations acted legally and properly in referring the appeal in a certification election case to the TUCP for possible settlement.
RULING
The Supreme Court ruled the referral was glaringly illegal and void. The Labor Code vests original and exclusive authority to act on inter-union conflicts and representation cases in the Bureau of Labor Relations and the labor relations divisions, not in any private entity. Articles 259 and 260 mandate that certification cases and appeals therein must be decided within specific, short periods (20 and 15 working days, respectively) to ensure expeditious settlement of labor disputes. The Director’s act constituted an unlawful abdication and delegation of his adjudicatory jurisdiction to a private federation, directly contravening the Code’s mandatory timelines and policy against delay.
Furthermore, the Court emphasized that the original record of a labor case is an official public record. Its removal from the legitimate custodian and entrustment to a private person is improper and fraught with risk. The Director placed himself in an untenable position by having to request the return of the record. The Court ordered the responsible officers of the TUCP to return the original record to the Director within 48 hours and directed the Director to decide the appeal within ten days from its receipt. Costs were imposed on the TUCP.