Superintendent v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The La Loma Catholic Cemetery, administered by the Roman Catholic Archbishop of Manila, operates as a religious temporality primarily for the burial of the dead. While it derives income from the sale and rental of burial lots and niches, and charges fees for registration, these proceeds are dedicated to the cemetery's maintenance and improvement. The cemetery also provides free burials for indigents and requires its personnel to observe religious obligations, including attending mass. The core dispute centers on whether this operation, despite generating income, constitutes a profit-making enterprise subject to labor laws. Procedural History: The La Loma Catholic Cemetery Free Workers (FFW) filed a petition with the Court of Industrial Relations (CIR) seeking certification as the sole bargaining representative for cemetery employees under Republic Act No. 875. The cemetery's superintendent moved to dismiss the petition, arguing that RA 875 does not apply to religious temporalities or non-profit enterprises. The CIR initially deferred ruling on the motion and ordered an answer. After the cemetery filed its answer, the CIR issued an order on June 28, 1957, holding that RA 875 applies, that the cemetery is an employer operating for profit, and certifying the FFW as the bargaining representative. A motion for reconsideration was denied by the CIR en banc on December 11, 1957, leading to the present appeal by certiorari. The Petition: The Superintendent of the La Loma Catholic Cemetery filed this appeal by certiorari, challenging the CIR's resolution and order. The petitioner contends that the La Loma Catholic Cemetery is a non-profit religious temporality and, therefore, not subject to the provisions of Republic Act No. 875. The petitioner argues that the CIR erred in finding the cemetery to be operated for profit and consequently lacked jurisdiction to certify the FFW as the exclusive bargaining representative. The appeal relies on prior Supreme Court decisions establishing that employees of non-profit organizations are not covered by the Industrial Peace Act.
Issue(s)
Whether the Court of Industrial Relations (CIR) has jurisdiction over a religious temporality like the La Loma Catholic Cemetery under the Industrial Peace Act (Republic Act No. 875). Whether the collection of fees for burial lots and niche rentals constitutes 'operating for profit' so as to bring a religious entity within the ambit of labor relations laws.
Ruling
The resolution and order appealed from are reversed, and the case is hereby dismissed, without costs.
Ratio Decidendi
On Issue 1: The Court ruled that the Court of Industrial Relations (CIR) lacks jurisdiction, strictly adhering to the precedent set in Boy Scouts of the Philippines v. Araos. In that case, it was established that the Industrial Peace Act (Republic Act No. 875) does not cover employees of non-profit organizations or institutions. The Court emphasized that for the CIR to exercise authority over a petition for certification, the employer must be engaged in an industrial or commercial undertaking for profit. Because the La Loma Catholic Cemetery is maintained by a corporation sole for purely religious objectives—specifically the burial of the dead according to Catholic rites—it is not an 'industrial' employer. The Court noted that despite the personal dissent of the ponente in the Araos case, the doctrine must be followed as long as it has not been reversed. Consequently, the Union's petition for certification cannot be entertained by the CIR. On Issue 2: The Supreme Court found that the CIR's conclusion that the cemetery operated 'for profit' was not supported by substantial evidence. Citing Jesus Sacred Heart College v. Collector of Internal Revenue, the Court held that every responsible organization must strive to operate within its resources and avoid a deficit, meaning a surplus or 'net income' does not automatically prove a commercial purpose. Similarly, following American Bible Society v. City of Manila, the fact that fees are charged for religious items or services (like burial plots) does not transform the activity into a business for profit. The evidence showed that the income derived was dedicated solely to the maintenance and improvement of the cemetery and that religious obligations were imposed on the workers. Since the cemetery also provides free services for indigents and is tax-exempt due to its religious nature, it remains a non-profit enterprise exempt from the Industrial Peace Act.
Main Doctrine
A religious temporality, such as a cemetery operated primarily for religious objectives and not for profit, is not subject to the provisions of the Industrial Peace Act (Republic Act No. 875), and the Court of Industrial Relations lacks jurisdiction over petitions for certification as exclusive bargaining representative filed by labor organizations within such entities.