Brillo v. Buklatan
REITERATIONFacts
The Antecedents: Plaintiff, Espiridion M. Brillo, as President of the Leyte United Workers (LUW), a registered labor union, filed a complaint against several defendants. The first cause of action sought the recovery of money collected by foremen from laborers as contributions to the LUW funds. The second cause of action alleged a breach of contract by International Trust Corporation and Pacific Copra Export Company, who purportedly agreed to a 20% wage increase for LUW members but failed to comply. The third cause of action sought a writ of certiorari against the Secretary of Labor for granting licenses to two new labor unions, Leyte Stevedoring and Terminal Dock Workers Union and Visayan Workers Union, alleging this action was detrimental to LUW and constituted grave abuse of discretion. The fourth cause of action was for declaratory relief on similar issues as the third. Procedural History: The defendants filed a motion to dismiss the complaint. The trial court granted the motion and dismissed the complaint. The Appeal: Plaintiff-appellant appealed the order of dismissal to the Supreme Court, arguing that the trial court erred in dismissing the complaint on the grounds raised by the defendants.
Issue(s)
Whether the President of a labor union can sue in his own name for the recovery of union funds. Whether the justice of the peace court has jurisdiction over the claims in the first cause of action. Whether the Leyte United Workers can pursue a claim based on an abandoned agreement before the Court of Industrial Relations. Whether the Secretary of Labor's act of granting licenses to new labor unions is subject to a writ of certiorari.
Ruling
The Supreme Court affirmed the order of dismissal. It held that the labor union, being a juridical entity, should have sued in its own name. The claims in the first cause of action, being individual and below P2,000.00, should have been filed in the justice of the peace court. The Court also found that the second cause of action was rendered moot by the abandonment of the agreement and the subsequent proceedings before the Court of Industrial Relations. Finally, the Court ruled that the Secretary of Labor's act of granting licenses is not a judicial function and thus not subject to certiorari.
Ratio Decidendi
On Issue 1: The Court held that the Leyte United Workers, being a duly registered labor union under Commonwealth Act No. 213, possesses juridical capacity to sue. Consequently, any action to recover funds belonging to the union must be brought in its own name, not in the name of its president. This aligns with the principle that a corporation or juridical entity acts through its authorized representatives but must be the party plaintiff in its own right. The plaintiff, by admitting the union's capacity to sue, implicitly acknowledged that the action should have been filed by the union itself, as mandated by Rule 3, Section 2 of the Rules of Court. On Issue 2: The Court found that the first cause of action comprised separate claims against several defendants, each not exceeding P2,000.00. Under Section 88 of Republic Act No. 296, such claims fall within the exclusive original jurisdiction of the justice of the peace court. Furthermore, the Court noted that these several claims did not appear to arise from the same transaction or series of transactions, nor were there common questions of law or fact warranting their joinder under Rule 3, Section 6 of the Rules of Court. Therefore, if new complaints were to be filed, they should be instituted in the appropriate justice of the peace court. On Issue 3: Regarding the second cause of action, the Court observed that the Leyte United Workers had already sought wage increases before the Court of Industrial Relations (CIR). The union had abandoned the alleged agreement for a 20% increase after the defendant corporations denied its existence, and instead pursued a general 50% increase, which the CIR did not grant. Under these circumstances, the union could not subsequently press its claim based on the abandoned 20% agreement, especially since the CIR is the court with the proper jurisdiction over such labor disputes and wage adjustments. On Issue 4: The Court ruled that a petition for certiorari under Rule 65 of the Rules of Court was not the proper remedy against the Secretary of Labor's act of granting licenses to new labor unions. This is because the Secretary of Labor, in issuing such licenses, does not exercise a judicial function but rather an administrative one. Certiorari is directed against acts of a tribunal, corporation, board, or officer exercising judicial, quasi-judicial, or ministerial functions. Moreover, the Court noted the absence of any allegation that the newly organized unions intended to undermine the constituted Government or violate Philippine laws, which would be grounds for denying registration under Section 2 of Commonwealth Act No. 213.
Main Doctrine
The Supreme Court affirmed the dismissal of the complaint, reiterating that a duly registered labor union has the legal personality to sue in its own name. It also clarified that claims below P2,000.00, not arising from a common transaction, fall within the exclusive jurisdiction of the justice of the peace court. Moreover, the Court held that the grant of licenses to labor unions by the Secretary of Labor is an administrative function, not a judicial one, and thus not subject to a writ of certiorari unless there is a clear showing of grave abuse of discretion amounting to excess of jurisdiction, which was not present in this case.