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COASTAL SUBIC BAY TERMINAL v. DEPARTMENT OF LABOR

FACTS:

Coastal Subic Bay Terminal, Inc. Rank-and-File Union (CSBTI-RFU) and Coastal Subic Bay Terminal, Inc. Supervisory Union (CSBTI-SU) separately filed petitions for certification election before the Department of Labor and Employment (DOLE) Regional Office. CSBTI-RFU claimed legitimacy as a labor organization with a charter certificate from ALU, while CSBTI-SU was chartered by APSOTEU. Both unions alleged that the company was unorganized. CSBTI opposed the petitions, arguing that the unions were not legitimate and the proposed bargaining units were not properly described. The Med-Arbiter dismissed the petitions but did not rule on the legitimacy of the unions. Both parties appealed to the Secretary of the DOLE, who recognized the legal personalities of CSBTI-RFU and CSBTI-SU and considered APSOTEU a legitimate labor organization. The Secretary ordered separate certification elections for the rank-and-file and supervisory employees. CSBTI filed a petition for certiorari before the Court of Appeals, which affirmed the decision of the Secretary. CSBTI then filed a petition for review on certiorari before the Supreme Court, raising issues regarding the registration of APSOTEU and the legal personality of CSBTI-SU. The Supreme Court ordered the parties to submit memoranda, but no record was found of such submissions.

ISSUES:

  1. Can the supervisory and the rank-and-file unions file separate petitions for certification election?

  2. Was the Secretary's decision based on stare decisis correct?

  3. Were private respondents engaged in commingling?

RULING:

  1. Yes, the supervisory and the rank-and-file unions can file separate petitions for certification election. The Secretary of the Department of Labor and Employment ruled that CSBTI-SU and CSBTI-RFU have separate legal personalities to file their separate petitions for certification election. The Secretary declared CSBTI-RFU and CSBTI-SU as legitimate labor organizations having been chartered respectively by ALU and APSOTEU after submitting all the requirements with the Bureau of Labor Relations (BLR). Therefore, separate certification elections should be conducted for the rank and file employees and the supervisory employees.

  2. The Secretary's decision based on stare decisis was not discussed in the case digest.

  3. The issue of whether private respondents were engaged in commingling was not discussed in the case digest.

PRINCIPLES:

  • Labor Code Article 235 provides that applications for registration shall be acted upon by the Bureau, which refers to the BLR and/or the Labor Relations Division in the Regional Offices of the Department of Labor.

  • The 1989 Revised Implementing Rules of the Labor Code (Implementing Rules) provide that the Bureau is authorized to process applications and issue certificates of registration.

  • The separate legal personalities of labor organizations can be recognized if they have submitted all the requirements with the BLR and have been duly registered.