Goodrich Philippines v. Goodrich (Marikina Factory) Confidential
REITERATIONFacts
The Antecedents: Respondent unions, B.F. Goodrich (Marikina Factory) Confidential and Salaried Employees Union-NATU and B.F. Goodrich (Makati Office) Confidential and Salaried Employees Union-NATU, sought recognition as bargaining agents. Petitioner, B.F. Goodrich Philippines, Inc., filed petitions for certification election. Subsequently, respondent unions filed strike notices demanding recognition. Petitioner alleged that on April 19 and 20, 1971, a strike was staged by those affiliated with private respondents to force recognition. Following a preliminary investigation, an unfair labor practice case (Case No. 5612-ULP) was filed against the members of the two unions for allegedly staging an illegal strike and committing unfair labor practices. Procedural History: Petitioner filed motions to hold in abeyance the hearings of the certification election cases pending the resolution of the unfair labor practice case. Petitioner argued that if the strike was declared illegal and members found guilty, they would lose their employee status and be disqualified from voting. Respondent Court of Industrial Relations, through Judge Ansberto Paredes, denied these motions, stating that the individual respondents were still employees with the right to self-organization and choice of bargaining representative, and that holding the proceedings in abeyance would deny them this statutory right. A motion for reconsideration was denied. The Petition: Petitioner filed a certiorari proceeding with the Supreme Court, arguing that the unfair labor practice case and the alleged illegal strike should be resolved before a certification election is held, as the employee status of the union members was in doubt. Respondent unions countered that a strike does not sever the employer-employee relationship and that petitioner engaged in union-busting tactics. They maintained that the striking employees remained qualified to vote.
Issue(s)
Whether the pendency of an unfair labor practice case filed by an employer against its employees for an alleged illegal strike warrants the postponement of a certification election. Whether the Court of Industrial Relations committed grave abuse of discretion in denying the employer's motion to hold in abeyance the certification election proceedings.
Ruling
The petition for certiorari is dismissed. The Court affirmed the order of the respondent Court of Industrial Relations denying the petitioner's motion to hold in abeyance the certification election proceedings.
Ratio Decidendi
On the issue of whether the pendency of an unfair labor practice case warrants the postponement of a certification election: The Supreme Court held that the situation presented was the reverse of established jurisprudence where a certification election is stayed pending inquiry into the bona fides of a labor union accused of company domination. In this case, it was the employer seeking to postpone the election pending resolution of an unfair labor practice case it filed against employees for an alleged illegal strike. The Court reasoned that allowing such postponement could dilute or fritter away the strength of labor organizations and prevent a free expression of employee will. The Court emphasized that the Industrial Peace Act aims for the earliest possible determination of the employees' bargaining representative, and that delaying this process under the guise of a pending employer-initiated ULP case could be used as a tool to impede union activities. The Court invoked the maxim lex dilationes semper exhorret (the law abhors delays), stating that there was no valid reason for the postponement sought. Furthermore, the Court noted that even if the employees were found to have engaged in an illegal strike, it does not automatically mean they forfeit their employment status, thus rendering the postponement potentially futile. The Court also pointed out that the law clearly contemplates that all employees should participate in a certification election, and unwarranted reductions in the number of participants should be avoided. On the issue of whether the Court of Industrial Relations committed grave abuse of discretion: The Supreme Court reiterated its long-standing doctrine that the discretion of the Court of Industrial Relations (now the National Labor Relations Commission) in matters of certification elections is broad and is rarely interfered with by appellate courts. Citing previous decisions, the Court stated that only a showing of clear abuse of discretion would warrant reversal. The Court found no such abuse in the present case, as the respondent Court's denial of the motion to hold in abeyance was based on sound legal reasoning aimed at upholding the employees' statutory right to choose their bargaining representative without undue delay or impediment. The Court also referenced decisions from the U.S. Supreme Court, which similarly accord a wide degree of discretion to labor tribunals in establishing procedures for fair and free elections.
Main Doctrine
The pendency of an unfair labor practice case filed by an employer against its employees for an alleged illegal strike does not serve as a bar to the holding of a certification election, as such postponement could be used by management to dilute the strength of labor organizations and prevent a free expression of employee will.