Bureau of Printing v. Bureau of Printing Employees Assn.
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns allegations of unfair labor practices by the Bureau of Printing, its Acting Secretary Serafin Salvador, and Director Mariano Ledesma, against employees of the Bureau of Printing. The complaint alleged that the petitioners interfered with, coerced, and discriminated against employees in the exercise of their right to self-organization and union activities. The petitioners denied these charges, asserting that the Bureau of Printing is a government agency performing governmental functions, not an industrial concern, and that some employees were suspended pending administrative investigation for breach of Civil Service rules. 2. Procedural History: The Bureau of Printing Employees Association (NLU) and several individuals filed a complaint for unfair labor practice against the petitioners. The petitioners moved to dismiss the case for lack of jurisdiction, arguing the Bureau of Printing is not an industrial concern. The Court of Industrial Relations (CIR) granted a preliminary hearing on jurisdiction and, in an order dated January 27, 1959, sustained its jurisdiction, deeming the Bureau's functions to be proprietary. A motion for reconsideration was denied by the CIR en banc. 3. The Petition: The petitioners filed a petition for certiorari and prohibition with preliminary injunction with the Supreme Court, seeking to annul the CIR's orders and to restrain further proceedings. They argued that the CIR lacked jurisdiction because the Bureau of Printing is a government agency performing governmental functions, not an industrial or business concern engaged for profit, and therefore not subject to the Industrial Peace Act. They also contended that the Bureau of Printing, lacking juridical personality, cannot be sued, and that the CIR's intervention would interfere with the executive branch's disciplinary functions over government employees.
Issue(s)
Whether the Court of Industrial Relations has jurisdiction over the Bureau of Printing in an unfair labor practice case. Whether the Bureau of Printing, by performing certain proprietary functions, becomes an industrial concern subject to the jurisdiction of the Court of Industrial Relations. Whether the Bureau of Printing, as a government office without juridical personality, can be sued.
Ruling
The petition is granted. The orders of the Court of Industrial Relations are set aside, and the complaint for unfair labor practice is dismissed.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations: The Supreme Court held that the Court of Industrial Relations (CIR) did not acquire jurisdiction over the Bureau of Printing. The Court reiterated its long-standing decisions that the CIR lacks jurisdiction to hear and determine complaints for unfair labor practice filed against institutions or corporations not organized for profit and, consequently, not industrial or business organizations. The Industrial Peace Act was intended to apply only to industrial employment and to govern the relations between employers engaged in industry and occupations for purposes of gain, and their industrial employees. The Bureau of Printing, as an office of the Government, operates under the direct supervision of the Executive Secretary and is charged with executing all printing and binding for the National Government. Its appropriations are provided for in the General Appropriations Act, and it is primarily a service bureau, not engaged in business or occupation for pecuniary profit. On the nature of the Bureau of Printing's functions: While acknowledging that the Bureau of Printing receives outside jobs and pays overtime, the Court found these facts insufficient to conclude that its functions are "exclusively proprietary in nature." Overtime work is performed only when the interest of the service requires it, and compensation is discretionary and dependent on appropriations. The private jobs undertaken are done upon request, not solicited, and only as Government work permits. These private jobs, which constitute a negligible percentage of the total work, are performed without profit. The Court emphasized that even if these additional jobs may be deemed proprietary in character, there was no showing that the employees performing them are separate from those employed in its general governmental functions. Therefore, the Bureau of Printing cannot be considered an industrial or business concern subject to the CIR's jurisdiction. On the Bureau of Printing's capacity to be sued: The Supreme Court affirmed that as an office of the Government without juridical personality, the Bureau of Printing cannot be sued. Any suit against it would effectively be a suit against the Government itself, which cannot be sued without its consent, especially over its objection. This principle is well-settled in jurisprudence. Furthermore, the case arose from administrative charges filed against officers of the respondent association for insubordination, grave misconduct, and acts prejudicial to public service. For the CIR to take cognizance of the case would mean interfering with the discharge of functions by executive officials authorized to institute and investigate administrative charges against subordinates.
Main Doctrine
The Court of Industrial Relations does not have jurisdiction over unfair labor practice cases filed against government instrumentalities performing governmental functions, even if they incidentally perform proprietary functions, as the Industrial Peace Act is intended to apply only to industrial employment for purposes of gain.