Blue Bar Workers' Union v. Lakas Ng Manggagawang Makabayan
REITERATIONFacts
The Antecedents: The Plum Federation of Industrial and Agrarian Workers (PLUM) petitioned the Court of Industrial Relations (CIR) for certification as the majority union and sole bargaining representative of rank-and-file employees at Blue Bar Coconut Philippines, Inc. The Blue Bar Workers' Union (petitioner), claiming to be a local affiliate of Lakas Ng Manggagawang Makabayan (Lakas) and having an existing collective bargaining agreement with the company, intervened in the case. The company confirmed the existence of the collective bargaining agreement. Procedural History: A consent election was held, supervised by CIR personnel, where petitioner Blue Bar Workers' Union-Lakas Ng Manggagawang Makabayan received 526 votes out of 714 cast, against PLUM's 155 votes. On July 17, 1968, CIR issued an order certifying Lakas as the sole bargaining agent, disregarding petitioner's name. Petitioner's motion for reconsideration was denied by CIR on August 26, 1968. Subsequently, petitioner's motion for reconsideration of these orders was denied by CIR en banc on October 3, 1968. Petitioner appealed to the Supreme Court. The Petition: Petitioner filed a petition for certiorari with a prayer for preliminary injunction, seeking to reverse and restrain the enforcement of the CIR's orders and resolution. Petitioner also filed a manifestation stating that Lakas was demanding a new collective bargaining agreement despite an existing one between petitioner and the company, and prayed for the preliminary injunction to prevent actions that might affect the existing agreement. The Supreme Court issued a writ of preliminary injunction upon petitioner's filing of a bond.
Issue(s)
Whether the Court of Industrial Relations gravely abused its discretion in issuing the questioned orders and resolution. Whether the subsequent developments mooted the controversy.
Ruling
The Supreme Court declared the Blue Bar Workers' Union as the sole bargaining representative of the rank-and-file employees of Blue Bar Coconut Philippines, Inc. The preliminary injunction previously issued was made permanent. No costs were awarded.
Ratio Decidendi
On Issue 1: The Court did not directly rule on the alleged grave abuse of discretion by the CIR in its initial orders. However, the subsequent voluntary withdrawal of claims by respondent Lakas Ng Manggagawang Makabayan (Lakas) rendered the controversy moot. Lakas, through a letter dated June 23, 1969, informed Blue Bar Coconut Philippines, Inc. that it was giving up all its rights, claims, and interests in the issue of union recognition in favor of the Blue Bar Workers' Union. This development obviated the need for the Court to definitively rule on the CIR's actions, as the parties themselves had reached a resolution. On Issue 2: The controversy was rendered moot by the subsequent actions of respondent Lakas. In a letter dated June 23, 1969, Lakas informed the employer, Blue Bar Coconut Philippines, Inc., that it was voluntarily relinquishing all its rights, claims, and interests in the issue of union recognition in favor of the petitioner, Blue Bar Workers' Union. Lakas requested the company to fully recognize the petitioner as the sole and exclusive bargaining representative. In view of this development, the petitioner filed a manifestation and motion praying for a decision recognizing it as the sole collective bargaining representative. Respondent Lakas failed to comment on this manifestation despite notice, effectively conceding the petitioner's claim. Consequently, the Court found no further dispute to resolve regarding union recognition.
Main Doctrine
The Supreme Court, in resolving a petition for certiorari, can make a preliminary injunction permanent and declare a union as the sole bargaining representative when the opposing union voluntarily withdraws its claims and requests the employer to recognize the petitioner union. This development effectively ends the controversy, rendering the prior orders of the Court of Industrial Relations moot.