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TOYOTA MOTORS PHILIPPINES CORPORATION LABOR UNION v. TOYOTA MOTOR PHILIPPINES CORPORATION EMPLOYEES UNION

FACTS:

The case involves a petition for certiorari seeking to set aside the Resolution and Order issued by the Secretary of Labor and Employment, which affirmed the dismissal of the Petition for Certification Election filed by respondent Toyota Motor Philippines Corp. Employees and Workers Union (TMPCEWU) and the Petition-in-Intervention filed by petitioner Toyota Motor Philippines Corp. Labor Union (TMPCLU). TMPCEWU filed its petition on April 24, 1997, while TMPCLU filed a motion to intervene on May 13, 1997. TMPCLU argued that TMPCEWU's petition was premature due to an earlier resolution ordering a certification election among rank-and-file employees represented by TMPCLU. TMPCLU also claimed that TMPCEWU's proposed bargaining unit violated the "single or employer" unit policy. TMPCLU argued that it had the legal personality to intervene based on its certificate of registration. On February 24, 1998, the Med-Arbiter dismissed both the petition for certification election and the petition-in-intervention. The Med-Arbiter found that TMPCLU's registration certificate was void ab initio because its membership at the time of registration included both supervisory and rank-and-file employees. Dissatisfied with the decision, TMPCLU appealed to the Secretary of Labor, who affirmed the dismissal of the petitions.

ISSUES:

  1. Whether petitioner had legal personality on October 30, 1997, when it filed its Petition-in-Intervention.

  2. Whether petitioner is required to register anew despite allegedly purging supervisory employee-members.

  3. Whether the labor organization, TMPCLU, had legal personality to file the Petition for Certification Election.

  4. Whether the issuance of a certificate of registration is proof of legal personality to file a Petition for Certification Election.

  5. Whether or not there was a valid dismissal of the petition for certification election.

  6. Whether or not there was compliance with the registration requirements of the Labor Code.

RULING:

  1. Petitioner did not have legal personality on October 30, 1997, when it filed its Petition-in-Intervention. The Supreme Court ruled in a previous case involving the same parties that petitioner had not attained the status of a legitimate labor organization because its bargaining unit included supervisory employees, which is prohibited under Article 245 of the Labor Code. Petitioner failed to register anew and did not provide evidence that it had purged its membership of supervisory employees.

  2. Yes, petitioner is required to register anew despite allegedly purging supervisory employee-members. The Supreme Court, in the same previous case, held that the purging of supervisory employees and the registration of the union as a new legitimate labor organization are necessary. This is because one of the requirements for registration is the submission of the list of officers, and some of petitioner's officers were supervisory employees.

  3. The labor organization, TMPCLU, did not have legal personality to file the Petition for Certification Election because its composition, being a mixture of supervisory and rank-and-file employees, was in direct violation of Art. 245 of the Labor Code.

  4. The issuance of a certificate of registration in favor of a labor organization is not an adequate proof of legal personality to file a Petition for Certification Election if the registration is vitiated by falsification and serious irregularities. The propriety of the registration can be challenged directly through cancellation of registration proceedings or indirectly by challenging the petition for the issuance of an order for certification election.

  5. The petition is dismissed for lack of merit. The assailed Resolution and Order of the Secretary of Labor and Employment affirming the decision of the Med-Arbiter are affirmed.

PRINCIPLES:

  • An employer is not precluded from ascertaining the legitimacy of a union before a certification election to ensure that the union is a duly registered labor organization representing the bargaining unit.

  • A labor organization that includes supervisory employees in its bargaining unit is not a legitimate labor organization.

  • In order to become a legitimate labor organization after purging supervisory employees, registration anew is necessary.

  • The submission of the list of officers is a requirement for the registration of a labor organization.

  • A labor organization's composition should not violate the prohibition of unions composed of both supervisory and rank-and-file employees under Art. 245 of the Labor Code.

  • A labor organization should be denied recognition as a legitimate labor organization if its application for registration is vitiated by falsification and serious irregularities.

  • The propriety of a labor organization's registration can be challenged directly through cancellation of registration proceedings or indirectly by challenging the petition for the issuance of an order for certification election.

  • The procedural requirements to impugn the registration of a labor organization should be adequately complied with.

  • The activities of labor organizations, associations, and unions are of public interest and must be protected.

  • Strict compliance with the registration requirements of the Labor Code is necessary.