G.R. No. L-69188 September 23, 1986
MIGUEL J. VILLAOR and CECILIO V. BAUTISTA, petitioners, vs. HON. CRESENCIANO B. TRAJANO, in his capacity as Director, Bureau of Labor Relations of the Ministry of Labor and Employment; OCTAVIO A. PINEDA, RAFAEL SAMSON, EDUARDO C. FLORA, MARIO S. SANTOS and CARLOS BANDALAN, respondents.

FACTS

Petitioners Miguel J. Villaor and Cecilio V. Bautista were proclaimed winners in the February 1984 election for president and vice-president, respectively, of the Philippine Air Lines Employees’ Association (PALEA). The defeated candidates, respondents Mario S. Santos and Carlos Bandalan, filed timely election protests with the PALEA Commission on Election (COMELEC), chaired by respondent Octavio Pineda. The protests alleged that segregated ballots in certain precincts were not counted and that members in the Cebu/Mactan area were disenfranchised due to a reduction of voting days from two to one. While these protests were pending, petitioners filed a case with the Ministry of Labor and Employment seeking the disqualification of the PALEA COMELEC members for partiality. The Med-Arbiter issued an order enjoining the opening of the contested ballot boxes.
Despite the injunction, the PALEA COMELEC proceeded to open the boxes and, on April 27, 1984, issued a resolution setting aside the petitioners’ proclamation. The resolution ordered the counting of the segregated votes and the holding of a special election in Cebu/Mactan for the positions of president, vice-president, and secretary. Petitioners moved to cite the COMELEC members for contempt and to annul the resolution. The Med-Arbiter subsequently issued orders on June 27 and August 1, 1984, annulling the COMELEC’s resolution and declaring the special election void. However, the Bureau of Labor Relations (BLR) Director, respondent Cresenciano B. Trajano, set aside the Med-Arbiter’s orders in a decision dated November 14, 1984, prompting this petition for review.

ISSUE

Whether the Bureau of Labor Relations Director erred in upholding the PALEA COMELEC’s resolution, which ordered a special election and the counting of segregated ballots, despite pending jurisdictional challenges and allegations of partiality.

RULING

The Supreme Court granted the petition, set aside the BLR Director’s decision, and revived the Med-Arbiter’s orders. The Court found the PALEA COMELEC’s actions to be tainted with grave abuse of discretion and partiality. First, the COMELEC blatantly violated the Med-Arbiter’s lawful injunction by proceeding to open the ballot boxes on April 25, 1984. This defiance demonstrated a disregard for proper legal processes and the authority of the labor relations machinery. Second, the order for a special election in Cebu/Mactan on May 4, 1984, lacked legal and factual basis. The Court agreed with the Solicitor General’s observation that the special election was a transparent maneuver to accommodate the defeated candidates, as petitioners’ winning margins were only 145 and 44 votes, respectively.
The legal logic rests on the principle that intra-union election disputes must be resolved with fairness and in accordance with established rules. The claim of disenfranchisement in Cebu/Mactan was unfounded, as a bulletin had been issued on February 15, 1984, announcing the one-day election, thereby providing due notice. Tradition alone does not create a vested right to a two-day election. Furthermore, the COMELEC’s decision to conduct a “piecemeal” special election while the legality of its actions was