Associated Labor Union v. Tabigne
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the eligibility of employees for a certification election at the Philippine Packing Corporation. A petition for such an election was initially filed by employees on December 28, 1966. Subsequent proceedings involved determining the appropriate voter list, with the Court of Industrial Relations (CIR) issuing resolutions regarding the payrolls to be used as a basis for eligibility. 2. Procedural History: The case originated with a petition for a certification election filed in December 1966. The CIR initially ordered the election, but this was followed by motions for reconsideration from the company and a union, raising issues about changes in employee rosters. The CIR, in an en banc resolution on June 11, 1969, modified the voter eligibility criteria by including the December 31, 1968 payrolls in addition to the December 31, 1966 payrolls. The Philippine Packing Corporation sought to appeal this resolution to the Supreme Court, but the petition was denied for lack of merit and became final. Despite this, the respondent union filed further motions on February 4, 1970, seeking to include and exclude specific employees from the voter list. The respondent judge then issued an order on February 16, 1970, cancelling the scheduled election and suspending proceedings indefinitely. 3. The Petition: The petitioner, Associated Labor Union, filed an original action for certiorari and prohibition with preliminary injunction against the CIR judge's order of February 16, 1970. The petitioner argues that the judge acted without jurisdiction and with grave abuse of discretion by cancelling the election and entertaining motions that sought to reopen and modify the CIR's final en banc resolution of June 11, 1969, which had already been upheld by the Supreme Court. The petition seeks to make the preliminary injunction permanent and compel the judge to proceed with the certification election based on the established voter lists.
Issue(s)
Whether respondent judge acted without jurisdiction or with grave abuse of discretion in cancelling the scheduled certification election and indefinitely suspending the same to entertain motions for inclusion and exclusion of voters that sought to modify a final and executory resolution.
Ruling
The writs of certiorari and prohibition are granted. The writ of preliminary injunction is made permanent. The respondent judge is directed to forthwith request the Department of Labor to conduct the certification election at the earliest possible date, using the payrolls of December 31, 1966, and December 31, 1968, as the basis for the voters' lists, without alteration or modification. The decision is immediately executory.
Ratio Decidendi
On Issue 1: The Court ruled that respondent judge acted beyond his authority and jurisdiction. The determination of eligible voters was conclusively decided by the CIR En Banc resolution of June 11, 1969, which the Supreme Court had already affirmed in G.R. No. L-30948. Applying the doctrine in Galvez v. Phil. Long Distance Telephone Co. (3 SCRA 418), the Court held that all issues passed upon in decisions or final orders that have become executory must be deemed conclusively disposed of. The respondent judge had no power to alter or modify the final ruling, as it constituted the 'law of the case' and was binding upon him. Furthermore, Section 12(c) of the Industrial Peace Act (Republic Act No. 875) makes it mandatory for the court to order an election upon a petition by at least ten percent of the employees. Allowing the postponement of the election to review voter lists based on alleged new 'environmental changes' would lead to interminable delays, potentially decimating the roster of petitioning employees through dismissals or replacements.
Main Doctrine
A respondent judge acts without jurisdiction or with grave abuse of discretion in cancelling a scheduled certification election and entertaining belated motions that seek to reopen a matter of eligible voters already conclusively decided in a final and executory en banc resolution of the Industrial Court, which was also upheld by the Supreme Court.