Davao Stevedores Mutual Benefit Association v. Compañia Maritima
REITERATIONFacts
The Antecedents: Compañia Maritima and Manila Steamship Co. operate vessels engaged in coastwise shipping. In Cebu and Mindanao ports, stevedoring work aboard these vessels is handled by local stevedores, while the wharf work, including arrastre, is handled by local stevedores. The Katubsanan sa Mamumuo, a labor union, has a contract with the shipping companies to furnish labor for stevedoring work aboard their vessels at Cebu and Mindanao ports. Procedural History: The Davao Stevedores Mutual Benefit Association (DSMBA) proposed to ship agents in Davao that DSMBA handle the stevedoring work on board their vessels while in Davao port, threatening to cause trouble if this proposal was not accepted. After mediation efforts by the Department of Labor failed, the dispute was certified to the Court of Industrial Relations. A writ of preliminary injunction was issued against DSMBA. The Court of Industrial Relations initially awarded the stevedoring work in Davao port to DSMBA members, but this decision was revoked by a resolution of the court en banc. The Petition: The DSMBA filed a petition to review the resolution of the Court of Industrial Relations that revoked the initial decision.
Issue(s)
Whether the Court of Industrial Relations erred in revoking its decision that awarded stevedoring work in Davao port to members of the Davao Stevedores Mutual Benefit Association. Whether a labor union can legally compel ship agents to contract exclusively with local laborers, excluding laborers from other regions.
Ruling
The resolution of the Court of Industrial Relations is affirmed. The petition is denied.
Ratio Decidendi
On the issue of awarding stevedoring work and excluding laborers from other regions: The Court held that the proposal of the petitioner, DSMBA, to exclude stevedores from Cebu and compel ship agents to contract exclusively with Davao stevedores lacks legal and rational support. There is no law granting such a right to laborers of a specific region. Such a measure would be against public policy as it promotes sectionalism and disunity. Furthermore, it would conflict with the equal protection clause of the Constitution and interfere with the citizen's right to freedom of contract, which are constitutionally guaranteed rights. The Court emphasized that the right to make a contract is an essential part of liberty, and both employers and employees have equal rights guaranteed by the Constitution. On the issue of addressing unemployment: The Court found that DSMBA's plea, based on the alleged lack of work for its members in Davao, to exclude laborers from other ports from their right to earn a living in Davao is an iniquitous proposal. It amounts to 'robbing Peter to pay Paul' and attempts to solve an alleged unemployment problem by ousting members of another labor union from their employment. The Court reiterated that claiming a right to live does not grant the petitioner the right to deny that same right to others.
Main Doctrine
A labor union's proposal to exclude laborers from other regions from employment opportunities based on their residence, and to compel ship agents to contract exclusively with local laborers, is contrary to law, public policy, and the constitutional guarantees of equal protection and freedom of contract.