University of San Agustin v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The Philippine Association of College and University Professors filed a complaint for unfair labor practice against the University of San Agustin (USA) before the Court of Industrial Relations (CIR). USA denied the charge and questioned the CIR's jurisdiction, arguing that its professors were not industrial laborers and that USA, being a religious non-stock corporation organized for educational purposes and not for profit, was not an industrial enterprise subject to the CIR's authority. Procedural History: A hearing was held, and USA raised the issue of lack of preliminary investigation. The CIR, through Judge Jose S. Bautista, issued an order on January 2, 1957, acknowledging the need for a preliminary investigation but asserting jurisdiction over the controversy, opining that industrial employment was not the sole criterion for its jurisdiction. The CIR ordered the case referred to its Prosecution Division for preliminary investigation. This order was affirmed by the CIR en banc. The Petition: USA filed a petition for review of the CIR's order and resolution, seeking to set aside the CIR's assertion of jurisdiction.
Issue(s)
Whether the Court of Industrial Relations has jurisdiction to entertain an Unfair Labor Practice (ULP) complaint against a non-stock, non-profit religious educational institution.
Ruling
The Court set aside the order and resolution of the Court of Industrial Relations, holding that it has no jurisdiction to entertain the complaint for unfair labor practices.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Court of Industrial Relations (CIR) lacks jurisdiction because Republic Act No. 875 (Industrial Peace Act) applies only to industrial employment for profit and gain. Relying heavily on the precedent set in Boy Scouts of the Philippines v. Juliana V. Araos (102 Phil. 1080), the Court held that labor legislation, from Commonwealth Act No. 103 to Republic Act No. 875, was intended by the Legislature to govern relations between employers in industry and their industrial employees. The University of San Agustin, being a religious non-stock corporation organized for lofty purposes such as education and instruction rather than profit, does not fit the legal definition of an 'industrial employer.' The Court emphasized that organizations operated for charity, social service, or education are excluded from the scope of the Act's provisions regarding labor disputes and unfair labor practices. Since there is a close analogy between the functions of the Boy Scouts and the University of San Agustin, the Court concluded that the CIR has no authority over the controversy. The Court further noted that the relation between the university and its professors in a non-profit context does not constitute the 'industrial' employment required for CIR jurisdiction. Applying the Araos doctrine, the Court clarified that any acts alleged to be unfair labor practices within such non-profit entities do not fall under the statutory jurisdiction of the Industrial Court.
Main Doctrine
The Court of Industrial Relations does not have jurisdiction over labor disputes and unfair labor practice complaints involving educational institutions organized not for profit, as Republic Act No. 875 applies only to industrial employment and profit-oriented enterprises.