## FACTS:

The case involves a petition for certiorari filed by the labor federation Ilaw at Buklod ng Manggagawa (IBM) for direct certification as the sole bargaining agent of the employees of SMFI-Cebu B-Meg Feeds Plant. IBM filed a petition for certification election claiming that no certification election had been conducted at SMFI and that the proposed bargaining unit, consisting of SMFI's monthly paid employees, is unorganized. SMFI filed a Motion to Dismiss, stating that a similar petition is pending between the same parties for the same cause of action. The Med-Arbiter granted IBM's second petition for certification election, leading SMFI to appeal the decision to the Secretary of Labor and Employment. Meanwhile, another issue arises regarding the legitimacy of the IBM Federation at SMFI as a labor organization, as it has not obtained a Certificate of Registration from the Bureau of Labor Relations. The petitioner argues that the authenticity of the charter certificate submitted by the respondent IBM cannot be confirmed. The respondent contends that the IBM Federation at SMFI is a legitimate labor organization duly registered with the Department of Labor and Employment. The main issue is whether the IBM Federation at SMFI is a legitimate labor organization with the right to be certified as the exclusive representative for collective bargaining purposes.

ISSUES

1. Whether the private respondent, Ilaw at Buklod ng Manggagawa (IBM) at SMFI, as a local or chapter of the IBM Federation, is a legitimate labor organization despite not having a separate certificate of registration from the Bureau of Labor Relations.

2. Whether the public respondent Undersecretary Laguesma committed grave abuse of discretion in affirming the Med-Arbiter's decision which allowed IBM at SMFI to proceed with a certification election.

RULING

1. The Supreme Court ruled that IBM at SMFI is a legitimate labor organization. It noted that under Article 212(h) of the Labor Code, a legitimate labor organization includes any branch or local thereof and does not need to hold a separate certificate of registration as long as it complies with the requirements for becoming a local chapter of a federation as provided under the Labor Code's Implementing Rules and Regulations.

2. The Court found no grave abuse of discretion committed by the public respondent, Undersecretary Laguesma, in upholding the Med-Arbiter’s decision to proceed with the certification election. The Court emphasized the principle of non-interference by employers in the selection process of a bargaining representative, underlying the purpose of a certification election as a fundamental element in promoting industrial democracy.

PRINCIPLES

1. Legitimacy of Labor Organization: Under Article 212(h) of the Labor Code, a labor organization, including any branches or locals, is considered legitimate if duly registered with the Department of Labor and Employment.

2. Certification Election: Protected as a democratic method for employees to choose their exclusive bargaining representative, certification elections should not be unduly delayed or hindered by employers, emphasizing the non-interference policy.

3. Complementary Provisions for Federation Locals: As per the Implementing Rules of the Labor Code, a local or chapter can achieve legitimate status upon submitting the required documents to the Bureau of Labor Relations, such as the charter certificate and pertinent organizational documents.

4. Role of Employer in Certification Elections: The Supreme Court outlines that the employer's role in certification elections is largely passive, reiterating that the process primarily involves and affects the employees.