Case No.

PALEA vs Hon. Ferrer-Calleja, GR No. 76673

FACTS:
A certification election was held on Apr. 27,1977 wherein petitioner Philippine
Airlines Employees Association (PALEA) won and was recognized by the Bureau of Labor
Relations (BLR) as the exclusive bargaining agent of all the rank and file employees of the
Philippine Airlines, Inc.
In 1980, respondent Philippine Airline Non-Managerial Employees Association
(PANOMEA-FUR) filed a petition for certification election among the administrative,
supervisory, licensed mechanics, technical and confidential employees of PAL , alleging
inter-alia that there is no other union existing in the proposed bargaining unit nor is there
a certified collective bargaining agreement which maybe a bar to the petition.
PALEA and PAL filed separate motions for reconsideration of the BLRs resolution
granting PANOMEAs petition.
While PAL and PALEAs motions for reconsideration were pending resolution by the
BLR director, the licensed mechanics whom PANOMEA sought to represent, filed their own
petition for certification election under the name of PAL Licensed / Amalgamated
Federation of Labor of the Philippines (PALMA-AFL).
In October 1985, the BLR Director dismissed the petition of the licensed mechanics
only (PALMA-AFL), excluding the administrative, supervisor, technical & confidential
employees, ruling that the existing law did not allow the creation of a separate bargaining
unit for the licensed mechanics.
However, in April 1986, the BLR Director ordered the holding of certification election
among the administrative, supervisory, licensed mechanics, technical & confidential
employees of PAL.
In this petition for certiorari, petitioner PALEA alleges that the BLR director erred in
ordering the certification election. PALEA claims that it is the exclusive bargaining
representative of all the rank & file employees and that PANOMEA seeks to dismember or
fragmentize the already existing bargaining unit so that another one may be created.
ISSUES:
1. W/N the BLR committed grave abuse of its discretion?
2. W/N PANOMEAs petition is meritorious?
HELD:
1. No, the BLR did not commit grave abuse of its discretion when it ruled that the
present CBA between PALEA and PAL covers only the rank & file employees but
not the licensed mechanics, administrative, supervisory, technical & confidential
employees of PAL.
The court held that as a rule, factual findings of the BLR which are supported by
substantial evidence are binding and must be respected by the courts.
2. Yes, PANOMEAs petition for certification election has merits. The Court held that
whenever there is doubt as to whether a particular union represents the majority
of the rank & file employees, in the absence of legal impediment, the holding of
certification election is the most democratic method of determining the
employees choice of their bargaining representative.