ACCFA vs.

CUGCO

FACTS:
On 4 Sept 1961 a CBA was agreed upon by labor unions (ASA and AWA) and ACCFA. The
said CBA was supposed to be effective on 1 July 1962. Due to non-implementation of the
CBA the unions held a strike on 25 Oct 1962. And 5 days later CUGCO, the mother union of
ASA and AWA filed a complaint against ACCFA due to unfair labor practices among others
which CUGCO was able to win in court. On 25 Apr 1963, ACCFA appealed the decision and
while the appeal was pending, RA 3844 was passed which effectively turned ACCFA to ACA.
On 17 Mar 1964, ASA and AWA then petitioned that they may have sole bargaining rights
with ACA. While this petition was not yet decided upon, on 19 March 1964, EO 75 was also
passed which placed ACA under the Land Reform Project Administration. Notwithstanding
the latest legislation passed, the trial court and the appellate court ruled in favor of ASA
and AWA.

ISSUE:
Whether or not ASA and AWA can be given sole bargaining rights with ACA.

HELD:
The Unions have no bargaining rights with ACA. EO 75 placed ACA under the LRPA and by
virtue of RA 3844 the implementation of the Land Reform Program of the government is a
governmental function NOT a proprietary function. Being such, ACA can no longer step
down to deal privately with said unions as it may have been doing when it was still ACCFA.
The growing complexities of modern society, however, have rendered this traditional
classification of the functions of government quite unrealistic, not to say obsolete. The
areas which used to be left to private enterprise and initiative and which the government
was called upon to enter optionally, and only "because it was better equipped to administer
for the public welfare than is any private individual or group of individuals,"
5
continue to
lose their well-defined boundaries and to be absorbed within activities that the
government must undertake in its sovereign capacity if it is to meet the increasing social
challenges of the times. Here as almost everywhere else the tendency is undoubtedly
towards a greater socialization of economic forces. Here of course this development was
envisioned, indeed adopted as a national policy, by the Constitution itself in its declaration
of principle concerning the promotion of social justice.