Benguet Consolidated, Inc. Employees and Workers Union v. Mountain Province Workers Union
REITERATIONFacts
The Antecedents: Respondent Mountain Province Workers Union filed a petition with the Court of Industrial Relations (CIR) on November 16, 1963, seeking a certification election among the rank-and-file employees of Benguet Consolidated, Inc.'s mining operations in Mountain Province. The petitioner, BCI Employees and Workers Union (PAFLU), was a party concerned with this petition. Procedural History: The CIR scheduled hearings for the certification election petition, with notices served to all concerned parties. The petitioner failed to appear at the initial hearing on January 11, 1964, despite proper notice. Subsequently, the petitioner filed an opposition on January 15, 1964, which was deemed filed out of time by the CIR and overruled on January 28, 1964. The petitioner's motion for reconsideration and attempts to suspend the election were denied by the CIR, including an en banc decision. The Petition: The petitioner seeks review of the CIR's order directing a certification election. The petitioner argues that the CIR disregarded its opposition and erroneously ordered a new election despite the petitioner having been certified as the collective bargaining unit in August 1962. The Supreme Court found no merit in these contentions, noting that the opposition was considered and denied on grounds of lateness, and that the lapse of over 15 months since the previous certification election justified a new election under Section 12 of Republic Act No. 875.
Issue(s)
Whether the Court of Industrial Relations committed grave abuse of discretion in ordering a certification election despite the petitioner's opposition being filed out of time. Whether the Court of Industrial Relations erred in ordering a new certification election when the petitioner was already certified as the collective bargaining unit in a previous election held on August 22, 1962.
Ruling
The petition for review was denied, and the order of the Industrial Court dated January 11, 1964, directing a certification election, was affirmed. No costs were awarded.
Ratio Decidendi
On Issue 1: The Court found no merit in the contention that the CIR acted in disregard of the opposition. While the opposition was filed after the order for election was dictated, the CIR did consider it in its subsequent order of January 28, 1964, denying the opposition on the ground of late filing. The Court noted that even if the ground for denial was lateness, the ruling itself was considered and acted upon, and a motion for reconsideration was also duly considered by the CIR en banc. Therefore, there was no complete disregard or ignoring of the opposition. On Issue 2: The Court ruled that the CIR did not err in ordering a new certification election. It cited Sections 12(b) and 12(d) of Republic Act No. 875, which permit a certification election to be ordered if more than 12 months have elapsed since the last certification election. In this case, the previous election was held on August 22, 1962, and the petition for a new election was filed more than 15 months later. This lapse of time justified the CIR's action. The Court also stated that the petitioner's inability to secure its own collective bargaining agreement within that period was its concern and did not preclude the ordering of a new election, as it had ample time to negotiate.
Main Doctrine
The Supreme Court affirmed the order of the Court of Industrial Relations for a certification election, holding that the petition was filed more than 15 months after the previous certification election in August 1962, thus complying with the 12-month period requirement under Section 12(b) and (d) of Republic Act No. 875. The Court found no grave abuse of discretion in the Industrial Court's handling of the opposition, noting that it was considered and denied, and that subsequent motions for reconsideration were also acted upon. The ruling emphasizes that the lapse of a sufficient period justifies a new certification election, irrespective of whether a collective bargaining agreement was secured.