G.R. No. L-9908; April 22, 1957
THE STANDARD CIGARETTE WORKER’S UNION (PLUM), petitioners, vs. THE COURT OF INDUSTRIAL RELATIONS, THE STANDARD CIGARETTE FACTORY AND “THE STANDARD WORKERS ORGANIZATION”, respondents.

FACTS

On September 25, 1954, the petitioner Standard Cigarette Workers’ Union (PLUM) filed charges of unfair labor practice against the Standard Cigarette Manufacturing Co., Inc. Pending preliminary investigation of this complaint, the same petitioner union filed a petition for a certification election on September 27, 1954. The respondent company answered, seeking dismissal of the petition on the grounds that a majority of its employees had already designated a rival union, the Standard Workers’ Organization, as their bargaining representative and that a collective bargaining agreement had already been executed with said rival union. The rival union intervened and moved to quash the petition. The Court of Industrial Relations (CIR) refused to dismiss the petition and set it for hearing. Subsequently, the CIR prosecutor filed a formal unfair labor practice complaint against the company on February 2, 1955. On March 9, 1955, the respondent company moved to suspend the hearing on the certification election pending final termination of the unfair labor practice case. The CIR granted the motion, ordering the suspension on the grounds that the unfair labor practice charges went into the root of the workers’ freedom to vote. The petitioner union’s motion for reconsideration was denied by the court en banc, prompting the union to file the present petition for certiorari.

ISSUE

Whether the Court of Industrial Relations acted with grave abuse of discretion in suspending the proceedings for a certification election pending the resolution of an unfair labor practice case filed by the same petitioner union against the employer company.

RULING

The Supreme Court granted the petition and set aside the CIR’s order. The Court ruled that an unfair labor practice case may be considered a prejudicial question warranting suspension of a certification election proceeding only when the charge alleges that a participating union is being aided or controlled by the employer (a company-dominated union). The rationale is to prevent a certification election that could result in the selection of an employer-dominated union, which would later be decertified, rendering the election proceedings useless. In this case, the petitioner union’s unfair labor practice complaint contained no charge that the rival Standard Workers’ Organization was being assisted or dominated by the company. The complaint primarily alleged that company officers failed to discourage union membership and dismissed some union members, aiming to deter such practices and secure reinstatement. Furthermore, it was the respondent company, not the petitioner union, that moved for suspension. The petitioner union opposed the suspension and was willing to proceed with the election, indicating it did not believe it would be prejudiced. The Court viewed the company’s move as a maneuver to delay the election, benefiting the rival union with which it had already concluded a collective bargaining agreement. The CIR was ordered to proceed with the hearing of the certification election case. Costs were imposed on the respondent Standard Workers’ Organization.