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PHILIPPINE SKYLANDERS v. NLRC

FACTS:

The Philippines Association of Free Labor Union (PAFLU) filed a complaint against Philippine Skylanders, Inc. (PSI) for unfair labor practice, accusing the company of refusing to engage in collective bargaining and interfering with union activities. The complaint also named the elected officers of the Philippine Skylanders Employees and Workers Association-PAFLU (PSEA-PAFLU) as additional respondents for allegedly being influenced by PSI's personnel manager. PSEA had disaffiliated from PAFLU and joined the National Congress of Workers (NCW), subsequently entering into a collective bargaining agreement with PSI. The Labor Arbiter declared PSEA's disaffiliation invalid and found PSI, PSEA-PAFLU, and their respective officers guilty of unfair labor practice. The Labor Arbiter also invalidated the collective bargaining agreement between PSI and PSEA-NCW. PSI, PSEA, and their officers appealed to the National Labor Relations Commission (NLRC), but the NLRC upheld the Labor Arbiter's decision.

ISSUES:

  1. Whether the disaffiliation of PSEA-PAFLU from PAFLU is valid.

  2. Whether PSI and its officers are guilty of unfair labor practice.

  3. Whether PAFLU has legal personality to file the complaint.

RULING:

  1. The disaffiliation of PSEA-PAFLU from PAFLU is invalid.

  2. PSI and its officers are guilty of unfair labor practice.

  3. PAFLU has legal personality to file the complaint.

PRINCIPLES:

  • Inter-union conflicts are within the jurisdiction of the Labor Arbiter.

  • A company may be held responsible for interfering with union activities.

  • The majority status of the incumbent bargaining agent can only be questioned within 60 days before the expiry of the collective bargaining agreement.