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TAKATA CORPORATION v. BUREAU OF LABOR RELATIONS

FACTS:

The case involves petitioner TAKATA Philippines Corporation filing a petition for the cancellation of the certificate of union registration against respondent Samahang Lakas Manggagawa ng Takata (SALAMAT). Petitioner alleged misrepresentation, false statements, and fraud regarding the number of attendees in the organizational meeting, the election of officers, and the adoption of the Constitution and By-Laws. Petitioner argued that only 68 individuals attended the meeting, falling short of the 20% membership requirement. Petitioner also claimed that the document "Pangalan ng mga Kasapi ng Unyon" did not have the signatures of the alleged 119 union members and that respondent did not submit the document "Sama-Samang Pahayag ng Pagsapi" at the time of the union registration application. Respondent denied the allegations and argued that the 119 union members fulfilled the membership requirement.

The Department of Labor and Employment (DOLE) Regional Director granted the petition for cancellation of respondent's certificate of registration, while the Bureau of Labor Relations (BLR) reversed the decision and upheld the registration.

The petitioner, SALAMAT, filed an application for registration with the BLR as a labor organization but was denied due to alleged non-compliance with the minimum membership requirement. The BLR claimed that only 68 out of the total 396 employees attended the organizational meeting, which was only 17% of the required number. The petitioner filed a motion for reconsideration, which was denied by the BLR. The petitioner then elevated the case to the Court of Appeals (CA) via a petition for certiorari. The CA affirmed the denial of the application for registration, and the petitioner filed a motion for reconsideration, which was also denied. The petitioner then filed a petition for review before the Supreme Court, raising issues of forum shopping and non-compliance with the law in the registration of the labor organization.

ISSUES:

  1. Whether or not the respondent committed forum shopping.

  2. Whether or not the petitioner's appeal is the only existing appeal with the Bureau of Labor Relations (BLR).

  3. Whether or not the cancellation of respondent's registration is justified on grounds of fraud and misrepresentation.

  4. Whether the respondent committed misrepresentation and fraud in securing its certificate of registration.

  5. Whether the respondent sufficiently complied with the membership requirement for registration.

  6. Whether or not the total number of employees in the bargaining unit is a significant factor in determining compliance with the required minimum membership.

RULING:

  1. The Court of Appeals (CA) found no error committed by the respondent in not committing forum shopping. The CA stated that the appellant, BMP Paralegal Officer Domingo P. Mole, no longer had the authority to file an appeal on behalf of union SALAMAT, as its services were already terminated. The CA concluded that the only appeal sanctioned by SALAMAT was the one filed by Atty. Napoleon C. Banzuela, Jr. and Atty. Jehn Louie W. Velandrez. Therefore, there is no forum shopping in this case.

  2. The Court held that Mole's appeal filed with the BLR, which was not specifically authorized by the respondent, is considered to have not been filed at all. The only existing appeal with the BLR was the one filed by Banzuela and Associates, which the Labor Secretary referred to the BLR. Hence, the BLR did not choose Banzuela and Associates' appeal over Mole's appeal.

  3. The Court found no merit in the petitioner's argument for the cancellation of respondent's registration on grounds of fraud and misrepresentation. The Court cited Article 234 of the Labor Code, which listed the requirements for registration. The Court stated that after the issuance of the certificate of registration, the cancellation of union registration could only be done through proceedings for cancellation of registration. The Court reasoned that the cancellation of registration can only be made on the grounds specified in Article 239 of the Labor Code.

  4. The Court found no evidence to support the petitioner's accusation of misrepresentation and fraud by the respondent in securing its certificate of registration. The Court held that allegations of misrepresentation and fraud must be supported by evidence and circumstances. The petitioner's allegation was based on the claim that there were only 68 employees present during the organizational meeting while the respondent claimed to have 119 members. However, the Court ruled that the 20% membership requirement for registration pertains to the employees' membership in the union and not to the list of workers who participated in the organizational meeting. The respondent submitted documents showing that it had more than 20% of the employees as union members, thus satisfying the requirement.

  5. The Court held that the alleged inclusion of an employee's name twice and the inclusion of a project employee in the list of union members did not constitute misrepresentation. The Court ruled that for misrepresentation to be a ground for the cancellation of union registration, it must be shown that there was a deliberate attempt to increase the union membership through false statements. The Court found that even without these names, the respondent had more than 20% of the rank-and-file employees as union members. Therefore, the Court concluded that the respondent had sufficiently complied with the membership requirement for registration.

  6. The Court affirmed the decision of the Court of Appeals denying the petition for review. The Court held that the total number of employees in the bargaining unit is of no moment as long as the union is able to comply with the 20% minimum membership requirement. Even if there is a discrepancy in the total number of employees, it does not affect the fact that the union has more than complied with the registration requirement.

PRINCIPLES:

  • Forum Shopping - The filing of multiple appeals on the same issue, in different forums, in order to secure a favorable decision or to harass the adverse party is prohibited.

  • Authorization to File Appeal - An appeal must be filed by a person or entity authorized to do so to have legal effect.

  • Cancellation of Union Registration - The certificate of registration of a legitimate labor organization may be cancelled by the Bureau of Labor Relations (BLR) on the grounds specified in Article 239 of the Labor Code, which include misrepresentation, false statement, or fraud in connection with the adoption or ratification of the constitution and by-laws.

  • Allegations of misrepresentation and fraud in securing a certificate of registration must be supported by evidence and circumstances.

  • The 20% membership requirement for registration pertains to the employees' membership in the union, not the list of workers who participated in the organizational meeting.

  • Misrepresentation for the purposes of canceling union registration must be grave and compelling enough to vitiate the consent of a majority of union members.

  • Inclusion of an employee's name twice and the inclusion of a project employee in the list of union members does not constitute misrepresentation unless there is evidence of a deliberate attempt to inflate union membership.

  • The total number of employees in the bargaining unit is not a significant factor in determining compliance with the required minimum membership for a registered union.

  • Compliance with the 20% minimum membership requirement is sufficient to fulfill the registration requirement.