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    Laguna Autoparts v. Secretary of Labor

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    Miguel Alleandro Alag
    The Supreme Court ruled in favor of the respondent union in three issues: (1) the respondent union was deemed a legitimate labor organization based on findings of the Secretary of Labor and Court of Appeals; (2) a union's legal personality cannot be collaterally attacked in a certification election petition, but must be done in a separate cancellation proceeding; and (3) the employer petitioner did not have legal standing to oppose the certification election petition, and could only participate as an observer. The Court upheld the decision to dismiss the employer's petition to nullify the certification election.

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    Laguna Autoparts v. Secretary of Labor

    Uploaded by

    Miguel Alleandro Alag
    457 views2 pages
    The Supreme Court ruled in favor of the respondent union in three issues: (1) the respondent union was deemed a legitimate labor organization based on findings of the Secretary of Labor and Court of Appeals; (2) a union's legal personality cannot be collaterally attacked in a certification election petition, but must be done in a separate cancellation proceeding; and (3) the employer petitioner did not have legal standing to oppose the certification election petition, and could only participate as an observer. The Court upheld the decision to dismiss the employer's petition to nullify the certification election.

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    Labor Relations Case Digest

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    The Supreme Court ruled in favor of the respondent union in three issues: (1) the respondent union was deemed a legitimate labor organization based on findings of the Secretary of Labor and Court of Appeals; (2) a union's legal personality cannot be collaterally attacked in a certification election petition, but must be done in a separate cancellation proceeding; and (3) the employer petitioner did not have legal standing to oppose the certification election petition, and could only participate as an observer. The Court upheld the decision to dismiss the employer's petition to nullify the certification election.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    457 views2 pages

    Laguna Autoparts v. Secretary of Labor

    Uploaded by

    Miguel Alleandro Alag
    The Supreme Court ruled in favor of the respondent union in three issues: (1) the respondent union was deemed a legitimate labor organization based on findings of the Secretary of Labor and Court of Appeals; (2) a union's legal personality cannot be collaterally attacked in a certification election petition, but must be done in a separate cancellation proceeding; and (3) the employer petitioner did not have legal standing to oppose the certification election petition, and could only participate as an observer. The Court upheld the decision to dismiss the employer's petition to nullify the certification election.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Laguna Autoparts v.

    Secretary of Labor

    G.R. NO. 157146, April 29, 2005

    Facts:

    Laguna Autoparts moved to dismiss the petition for certification election. It claimed that OBRERO
    PILIPINO-LAMCOR CHAPTER was not a legitimate labor organization for failure to show that it had
    complied with the registration requirements, such as the submission of some necessary requirements to
    the Regional Office or the Bureau of Labor Relations (BLR) and that its legal personality was at question.

    Med-Arbiter dismissed the petition for certification election for OBRERO PILIPINO’S lack of legal
    personality. The Med-Arbiter found that the respondent union had not yet attained the status of a
    legitimate labor organization because it failed to indicate its principal office on the documents it submitted
    to the Regional Office. He opined that this was a fatal defect tantamount to failure to submit the complete
    requirements, which warranted the dismissal of the petition for certification election.

    The respondent union appealed the case to the Secretary of Labor and Employment who reversed the
    decision of the med-arbiter. The Court of Appeals also affirmed the decision of the Secretary of Labor.

    Issues:

    (a) whether or not the respondent union is a legitimate labor organization; - YES

    (b) whether or not a chapter’s legal personality may be collaterally attacked in a petition for certification
    election; - NO and

    (c) whether or not the petitioner, as the employer, has the legal standing to oppose the petition for
    certification election.

    Held:

    First Issue

    Findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise
    because their jurisdiction is confined to specific matters, are generally accorded not only great respect but
    even finality. This is particularly true where the CA affirms such findings of fact. In this case, the CA
    affirmed the finding of the Secretary of Labor and Employment that the respondent union is a legitimate
    labor organization.

    Indeed, a local or chapter need not be independently registered to acquire legal personality this is
    pursuant to Section 3 Rule VI of the IRR of Book 5 as amended by D.O No. 9 which says that a
    local/chapter constituted in accordance with Section 1 of this Rule shall acquire legal personality from the
    date of filing of the complete documents enumerated therein.

    As gleaned from the said provision, the task of determining whether the local or chapter has submitted the
    complete documentary requirements is lodged with the Regional Office or the BLR, as the case may be.
    The records of the case show that the respondent union submitted the said documents to Regional Office
    No. IV and was subsequently issued CERTIFICATE OF CREATION OF LOCAL/CHAPTER.
    Hence, the Regional Office, through the Labor Relations Division Chief, has determined that the
    respondent union complied with the requirements under the law. It, therefore, declared that the
    respondent union has acquired legal personality as a labor organization.

    2nd Issue

    Section 5, Rule V of D.O. 9 is instructive on the matter. It provides that the legal personality of a union
    cannot be the subject of collateral attack in a petition for certification election, but may be questioned only
    in an independent petition for cancellation of union registration. This has been the rule since NUBE v.
    Minister of Labor, 110 SCRA 274 (1981). What applies in this case is the principle that once a union
    acquires legitimate status as a labor organization, it continues as such until its certificate of registration is
    cancelled or revoked in an independent action for cancellation.

    Equally important is Section 11, Paragraph II, Rule IX of D.O. 9, which provides for the dismissal of a
    petition for certification election based on the lack of legal personality of a labor organization only in the
    following instances: (1) appellant is not listed by the Regional Office or the BLR in its registry of legitimate
    labor organizations; or (2) appellant’s legal personality has been revoked or cancelled with finality. Since
    appellant is listed in the registry of legitimate labor organizations, and its legitimacy has not been revoked
    or cancelled with finality, the granting of its petition for certification election is proper.

    Third Issue

    Finally, on the issue of whether the petitioner has the legal standing to oppose the petition for certification
    election, we rule in the negative.

    Its role in a certification election has aptly been described in Trade Unions of the Philippines and Allied
    Services (TUPAS) v. Trajano, as that of a mere bystander. It has no legal standing in a certification
    election as it cannot oppose the petition or appeal the Med- Arbiter’s orders related thereto.

    Therefore in conclusion:

    There is no reversible error in the CA’s decision dismissing the petition for certiorari for the nullification of
    the decision of the Secretary of Labor and Employment.

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