Balmar Farms, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Balmar Farms, Inc. (BALMAR) is a corporation engaged in planting bananas, and the Associated Labor Union (ALU) is a registered labor organization. On October 27, 1982, ALU was certified as the sole and exclusive bargaining representative of BALMAR's rank and file workers. In November 1982, BALMAR received a letter from Johnny Y. Luces, President of the BALMAR Employees Association, stating a majority of employees wished to disregard ALU and negotiate directly with management. On February 8, 1983, ALU submitted its collective bargaining agreement (CBA) proposals. BALMAR refused to negotiate on February 25, 1983, citing the disaffiliation letter. ALU asserted its status on March 1, 1983, and BALMAR reiterated its refusal on March 10, 1983, stating the Balmar Farms Employees Association requested direct negotiation due to ALU's dis-authorization. Procedural History: ALU filed a complaint for unfair labor practice and damages against BALMAR for refusal to bargain. The Labor Arbiter found BALMAR guilty of unfair labor practice on March 13, 1984, ordering it to cease and desist and bargain collectively with ALU, while dismissing the damages claim. BALMAR appealed to the National Labor Relations Commission (NLRC), which dismissed and affirmed the Labor Arbiter's decision en toto on July 31, 1985. BALMAR's motion for reconsideration was denied by the NLRC on October 4, 1985. The Petition: This petition for certiorari seeks to reverse and set aside the resolutions of the NLRC.
Issue(s)
Whether petitioner BALMAR is guilty of unfair labor practice for refusing to bargain collectively with ALU.
Ruling
The petition is dismissed for lack of merit, and the assailed resolution of the NLRC is affirmed.
Ratio Decidendi
On the issue of whether petitioner BALMAR is guilty of unfair labor practice for refusing to bargain collectively with ALU: The Court affirmed the NLRC's finding that BALMAR was guilty of unfair labor practice because ALU was certified as the sole and exclusive bargaining representative of BALMAR's rank and file employees following a certification election where ALU obtained the majority of votes. Employees have a constitutional right to choose their bargaining representative, and ALU, as the certified exclusive bargaining representative, had the right and duty to bargain collectively with BALMAR. BALMAR's refusal to negotiate, based on a letter from an employee claiming disaffiliation from ALU without any superseding order, and BALMAR's action of taking sides with the employees who allegedly disaffiliated, constituted a clear act of unfair labor practice under Article 248(g) of the Labor Code.
Main Doctrine
An employer is guilty of unfair labor practice for refusing to bargain collectively with a union certified as the sole and exclusive bargaining representative, especially when the employer's refusal is based on a letter from employees purportedly disaffiliating from the union, without a superseding order from the Med-Arbiter.