University of the Philippines v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The respondent labor union and its members, Fabiana Borines, Epifania Abijay, and Alicia Ebalo, filed a complaint for unfair labor practice against petitioners University of the Philippines (UP) and Concepcion Anonas, the matron and officer-in-charge of the UP Women's South Dormitory. The complaint alleged that UP and Anonas discriminated against the three union members regarding their hire and tenure by not reappointing them in relation to their demands for better working conditions. Procedural History: Petitioners denied the charge, asserting that the employees' employment was temporary and they were not reappointed due to negligence, insubordination, and disloyalty. They moved to dismiss the case, arguing that UP, as a state agency performing governmental functions and being a non-profit organization, was not subject to Republic Act No. 875. The motion to dismiss was denied. A motion for reconsideration, filed by the Solicitor General, was also denied for being filed out of time. Reconsideration of this resolution was likewise denied. The Petition: Petitioners filed a petition for certiorari with preliminary injunction, seeking to annul the orders of the respondent Court of Industrial Relations (CIR) and to restrain it from proceeding, on the grounds of lack of jurisdiction and failure to state a cause of action.
Issue(s)
Whether the University of the Philippines falls under the jurisdiction of the Court of Industrial Relations. Whether the complaint for unfair labor practice states a valid cause of action.
Ruling
The petition for certiorari is granted. The orders complained of are set aside, and the complaint for unfair labor practice against the petitioners is dismissed.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations: The Court held that the University of the Philippines, established to provide advanced instruction and professional/technical training, performs a legitimate governmental function and is maintained by the Government. It does not declare dividends and is not a corporation created for profit. Citing Boy Scouts of the Philippines vs. Araos and University of Santo Tomas vs. Villanueva, the Court reiterated that labor legislation, including Republic Act No. 875 concerning labor disputes and unfair labor practices, was intended to apply only to industrial employment and profit-making entities, not to organizations maintained for elevated purposes such as education. Therefore, the CIR lacked jurisdiction to hear the unfair labor practice complaint against the petitioners. On the failure to state a valid cause of action: The Court found that the complaint itself showed that the complaining union members were temporary employees whose period of employment had terminated. The complaint alleged that petitioner Anonas did not recommend the renewal of their appointments because she had lost confidence in them. Settled jurisprudence dictates that temporary appointees have no fixed tenure and their employment can be terminated at the pleasure of the appointing power without the need to show cause. Thus, their separation from service was justified, and the complaint failed to state a valid cause of action.
Main Doctrine
The University of the Philippines, performing a governmental function and not being organized for profit, is not subject to the jurisdiction of the Court of Industrial Relations under Republic Act No. 875. Furthermore, temporary employees have no fixed tenure and their employment can be terminated at the pleasure of the appointing power without need for cause.