FACTS:
The Samahang Manggagawa sa St. James School of Quezon City ("Samahang Manggagawa") filed a petition for certification election to determine the collective bargaining representative of the motor pool, construction, and transportation employees of St. James School of Quezon City. The certification election was held on June 26, 1999, with 149 eligible voters and 84 voters casting their votes. St. James School filed a certification election protest, claiming that the 84 votes were cast by construction workers of an independent contractor, Architect Conrado Bacoy, and not its regular employees. Med-Arbiter Tomas F. Falconitin ruled that the 84 voters were no longer working at St. James at the time of the certification election. Med-Arbiter Falconitin further ruled that even if the 84 workers were included in the total number of employees, the total number of voters would not constitute a majority of all eligible voters. The Department of Labor and Employment (DOLE) reversed the ruling of Med-Arbiter Falconitin on appeal and directed the opening of the challenged ballots. St. James School filed a motion for reconsideration, but it was denied by the DOLE. St. James School then filed a special civil action before the Court of Appeals, which dismissed the petition. As a result, St. James School brought a petition for review before the Supreme Court, questioning the validity of the formation of the labor union and the validity of the certification election.
ISSUES:
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Whether St. James is allowed to question the validity of the formation of the labor union.
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Whether the certification election is valid.
RULING:
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St. James may no longer question the validity of the formation of the labor union.
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The certification election is valid.
PRINCIPLES:
- Once a certification election has been held and the results have been certified by the DOLE, the employer is no longer allowed to question the validity of the formation of the labor union (Doctrine of Certification Election).