University of Santo Tomas Hospital v. U.S.T. Hospital Employees Association
REITERATIONFacts
The Antecedents: The University of Santo Tomas Hospital (USTH) was charged with unfair labor practice acts against Felipe L. Torrecampo, president of the University of Santo Tomas Employees Association, in violation of Section 4(a), paragraphs 1 and of Republic Act 875. Procedural History: USTH filed a motion to dismiss, alleging lack of jurisdiction and inapplicability of Republic Act 875. The Court of Industrial Relations (CIR) denied the motion, holding that it had jurisdiction and that RA 875 applies to non-industrial establishments. This ruling was upheld by the CIR en banc. The Petition: USTH appealed the CIR's decision to the Supreme Court.
Issue(s)
Whether the Court of Industrial Relations (CIR) has jurisdiction to hear an unfair labor practice case against a non-profit hospital owned and operated by an educational institution under Republic Act No. 875.
Ruling
The decision of the Court of Industrial Relations is reversed, and the complaint for unfair labor practice against petitioner is dismissed.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Court of Industrial Relations (CIR) did not have jurisdiction over the unfair labor practice complaint because the petitioner is a non-profit institution. The Court applied the principle established in Boy Scouts of the Philippines v. Araos, which clarified that Republic Act (RA) No. 875 was intended by Congress to govern relations only between employers engaged in industry for profit and their industrial employees. The Court reasoned that entities operated for social service, education, and medical service without the intent for gain are excluded from the Act's provisions regarding labor disputes. Since the University of Santo Tomas (UST) Hospital is owned and operated by a university exclusively for education and not for profit, it cannot be classified as an industrial employer. The Court noted that this interpretation had been consistently applied in subsequent cases like University of San Agustin v. CIR and The Elks Club v. The United Laborers & Employees of the Elks Club. Consequently, because the hospital is a non-industrial and non-profit establishment, the relationship between the hospital and its employees is not governed by the Industrial Peace Act. Thus, the CIR exceeded its authority in assuming jurisdiction over the alleged unfair labor practices committed by the hospital.
Main Doctrine
Republic Act No. 875, the Industrial Peace Act, does not apply to non-industrial establishments or entities organized, operated, and maintained not for profit or gain, such as charitable or educational institutions, including hospitals owned and operated by educational institutions.