FEU-Dr. Nicanor Reyes Medical Foundation vs.
Trajano 6/6/24, 2:34 PM
Title
FEU-Dr. Nicanor Reyes Medical Foundation vs. Trajano
Case Ponente Decision Date
G.R. No. 76273 PARAS, J Jul 31, 1987
A non-pro!t medical institution in the Philippines !les a petition opposing the
formation of a labor union by its employees, but the Supreme Court dismisses the
petition and a"rms the decision to allow the certi!cation election, citing an
amendment to the Labor Code that permits rank and !le employees of non-pro!t
medical institutions to form labor unions.
Case Digest (G.R. No. 76273)
GPT-4o (v3)
Facts:
The case involves the petitioner, Far Eastern University-Dr. Nicanor Reyes Medical
Foundation, Inc., a non-stock, non-pro!t medical institution with approximately 350 rank
and !le employees, most of whom are members of the respondent Alliance of Filipino
Workers (AFW). On February 13, 1986, AFW !led a Petition for Consent and/or Certi!cation
Election with the Ministry of Labor and Employment. The petitioner opposed this petition,
arguing that a similar petition involving the same issues and parties was pending
resolution before the Supreme Court (G.R. No. L-49771). The history of the case reveals that
as early as May 10, 1976, AFW had !led a similar petition, which was denied by the Med-
Arbiter and the Secretary of Labor on appeal, based on Article 244 of the Labor Code, which
at that time did not allow employees of non-stock, non-pro!t institutions to form unions.
AFW then !led a petition for certiorari with the Supreme Court, challenging the
constitutionality of Article 244. However, before the Supreme Court could resolve the issue,
Batas Pambansa Bilang 70 was enacted on May 1, 1980, amending Article 244 to allow
employees of non-pro!t institutions to form unions. Consequently, AFW !led another
petition for certi!cation election on February 13, 1986. On April 17, 1986, the Med-Arbiter
granted the petition, and the respondent Director a"rmed this decision on appeal,
declaring that the amendment rendered the previous constitutional challenge moot and
academic. The petitioner then !led this petition for certiorari, alleging that the respondent
Director gravely abused his discretion by granting the certi!cation election petition despite
the pending Supreme Court case.
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FEU-Dr. Nicanor Reyes Medical Foundation vs. Trajano 6/6/24, 2:34 PM
Issue:
1. Did the respondent Director gravely abuse his discretion in granting the petition for
certi!cation election despite the pendency of a similar petition before the Supreme
Court involving the same parties and issues?
Ruling:
The Supreme Court dismissed the petition and a"rmed the decision of the respondent
Director to grant the petition for certi!cation election.
Ratio:
The Supreme Court held that the petition was devoid of merit. At the time AFW !led its
petition for certi!cation election on February 13, 1986, Article 244 of the Labor Code had
already been amended by Batas Pambansa Bilang 70. The amendment explicitly allowed
employees of non-pro!t medical institutions to form, join, or organize labor unions for
collective bargaining purposes. The Court found that AFW had complied with the legal
requirements for calling a certi!cation election, and it was therefore incumbent upon the
respondent Director to conduct such an election to determine the bargaining
representative of the petitioner's employees. The Court also noted that the pending
Supreme Court case (G.R. No. L-49771) would not constitute res judicata for the certi!cation
election petition, as the former involved a constitutional challenge to Article 244 before its
amendment, while the latter invoked the amended version of the article. Finally, the Court
dismissed the petitioner's argument that the respondent Director should not have declared
the pending Supreme Court case moot and academic, stating that the Director had to make
a decision based on the current legal framework.
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