San Beda LAw

casE DIGEST IN LABOR RELATIONS

ATTY. FLORENCIO MAMAUAG JR.

RIGHTS OF LEGITIMATE LABOR ORGANIZATION

1. La Carlota Sugar Central vs. CIR (64 SCRA 79)

2. Golden Donuts, Inc. vs. NLRC (322 SCRA 294) 


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 San Beda LAw
casE DIGEST IN LABOR RELATIONS
ATTY. FLORENCIO MAMAUAG JR.

LA CARLOTA SUGAR CENTRAL v. COURT OF INDUSTRIAL RELATIONS,

NATIONAL SUGAR WORKERS UNION (PAFLU) and JOSE VILLANUEVA

G.R. No. L-20203, May 19, 1975

Fernando, J.
TOPIC: Article 251

Doctrine:
A labor union possesses the requisite personality to sue on behalf of its members
for their individual money claims. It would be an unwarranted impairment of the
right to self-organization if such collective entities are barred from instituting such
actions in their representative capacity.

Facts:
Petitioner assailed the order of respondent court awarding overtime pay to its
employees who rendered overtime services during Sundays and legal holidays. It
contended that the Court of Industrial Relations had no jurisdiction to pass upon
the issues involving money claims arising out of, or in connection with,
employment since the matter falls within the jurisdiction of the ordinary judicial
tribunals. Petitioner who alleged that procedural due process was not observed
because the employees whose statutory right for overtime pay as found in the
challenged order were not respected had not been included as parties.

Issue:
Whether or not CIR has jurisdiction over money claims for overtime on Sundays
and legal holidays by employees still forming part of the labor force of petitioner
firm, La Carlota Sugar Central

Held:
YES. The then existing Court of Industrial Relations had jurisdiction over all
claims such as those related to the Minimum Wage Law and the Eight-Hour Labor
Law provided that the employer-employee relationship was still in existence or
was sought to be reestablished because of its wrongful severance. Where the
employment had terminated and no reinstatement was sought, the claims
became mere money claims falling under the jurisdiction of the regular courts. A
labor union possesses the requisite personality to sue on behalf of its members
for their individual money claims. It would be an unwarranted impairment of the
right to self-organization if such collective entities are barred from instituting such
actions in their representative capacity. Once a collective contract is entered into,
its benefits extend not only to all the laborers and employees in the collective
bargaining unit, but also to those who do not belong to the labor organization
chosen to represent the employees. 


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 San Beda LAw
casE DIGEST IN LABOR RELATIONS
ATTY. FLORENCIO MAMAUAG JR.

GOLDEN DONUTS, INC. vs. NLRC

G.R. Nos. 113666-68. January 19, 2000
Pardo, J.
TOPIC: Article 251

Doctrine:
The union has no authority to compromise the individual claims of members who
did not consent to such settlement.

Facts:
Private respondents were the complainants in three consolidated cases submitted
with the Labor Arbiter. Complainants were members of the KMDD-CFW whose
CBA with the corporation expired. During the negotiations, the management
panel arrived late causing the union panel to walk out. The management
addressed a letter of apology to the union and requested for negotiations to
resume. The union panel did not show up despite letters from management
advising the former of the CBA meetings. The union struck. A compliant was filed
by Golden Donuts to declare the strike illegal. Counsel for the union and strikers
pleaded for a compromise whereupon both parties would desist from continuing
their cases against each other. The Labor Arbiter rendered a decision upholding
the dismissal of private respondents and ruling that they were bound by the
compromise agreement entered into by the union with petitioners. Private
respondents appealed to the NLRC, claiming that the union had no authority to
waive or compromise their individual rights and they were not bound by the
compromise agreement entered into by the union with petitioners.

Issues:
(1) May a union compromise or waive the rights to security of tenure and money
claims of its minority members, without the latters consent,; and
(2) whether or not the compromise agreement entered into by the union with
petitioner company, which has not been consented to nor ratified by respondents
minority members has the effect of res judicata upon them.

Held:
(1)Absent a showing of the union’s special authority to compromise the individual
claims of private respondents for reinstatement and backwages, there is no valid
waiver of the aforesaid rights. The judgment of the Labor Arbiter based on the
compromise agreement does not have the effect of res judicata upon private
respondents who did not agree thereto since the requirement of identity of
parties is not satisfied. A judgment upon a compromise agreement has all the
force and effect of any other judgment and is conclusive only upon parties thereto
and their privies. Private respondents have not waived their right to security of
tenure nor can they be barred from entitlement of their individual claims. Since
there was no evidence that private respondents committed any illegal act,

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 San Beda LAw
casE DIGEST IN LABOR RELATIONS
ATTY. FLORENCIO MAMAUAG JR.

petitioner’s failure to reinstate them after the settlement of the strike amounts to
illegal dismissal.

(2) The judgment of the Labor Arbiter based on the compromise agreement in
question does not have the effect of res judicata upon private respondents who
did not agree thereto. "A compromise, once approved by final orders of the court
has the force of res judicata between the parties and should not be disturbed
except for vices of consent or forgery." A compromise is basically a contract
perfected by mere consent. "Consent is manifested by the meeting of the offer
and the acceptance upon the thing and the cause which are to constitute the
contract." A compromise agreement is not valid when a party in the case has not
signed the same or when someone signed for and in behalf of such party without
authority to do so. Private respondents were not parties to the compromise
agreement. Hence, the judgment approving such agreement cannot have the
effect of res judicata upon them since the requirement of identity of parties is not
satisfied. A judgment upon a compromise agreement has all the force and effect
of any other judgment, hence conclusive only upon parties thereto and their
privies. Viewed in light of the foregoing legal principles, the conclusion is
inescapable that private respondents are not bound by the compromise
agreement entered into by the union without their consent. They have not waived
their right to security of tenure nor can they be barred from entitlement of their
individual claims.||| (Golden Donuts, Inc. v. National Labor Relations Commission,
G.R. Nos. 113666-68, [January 19, 2000], 379 PHIL 303-316)

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