SUBJECT: LABOR RELATIONS

Alliance of Natioinalist and Genuine Labor Org. (ANGLO for Brevity)

Vs.
Samahan ng mga Mangagawang Nagkakaisa sa Manila Bay Spinning Mills (SAMANA
BAY for Brevity)
GR No. 118562, July 5, 1996

FACTS:

ANGLO is a duly registered labor organization, while SAMANA BAY is its affiliate.

In representation of SAMANA BAY, ANGLO entered a CBA with Manila Bay Spinning Mills and
J.P. Coats Manila Bay, Inc. (herein referred to as Corporations)

SAMANA BAY decided to disaffiliate from ANGLO in view of the latters dereliction of duty to
promote and advance the welfare of the former and the alleged cases of corruption involving
federation officers. This disaffiliation was unanimously confirmed by the members of SAMANA
BAY.

But the corporations refused to honor SAMANA BAY resolution. Thus, SAMANA BAY filed a
petition to stop remittance of federation dues to ANGLO with the Bureau of Labor relations.

ANGLO counter-acted by unseating all officers and board members of SAMANA BAY and
appointing instead a new set of officers who were duly recognized by the corporations.

ANGLO contended that the disaffiliation is void considering that CBA is still existing and the
freedom period has not yet set in.

Med-Arbiter resolved that the disaffiliation is void but upheld the illegality of the ouster of the
officers of SAMANA BAY.

When both parties (ANGLO and SAMANA BAY) appealed to DOLE, the latter ruled that:

a. Disaffiliation is valid.
b. Directing the Corporations to stop remitting to ANGLO federation dues and instead to
remit the whole amount of union dues to the treasurer of SAMANA BAY; and
c. Enjoining ANGLO from interfering in the affairs of SAMANA BAY

ISSUES:

W/N disaffiliation is valid.

W/N ANGLO can validly oust the officers or board member of SAMANA BAY.

RULING:

Disaffiliaiton is valid. All employees enjoy the right to self-organization and to form and join
labor org. of their own choice for the purpose of Collective Bargaining. This is a fundamental
right of Labor and derives its existence from the Constitution. In interpreting the protection to
labor and social justice provision of the Constitution and Labor laws, it is always adopted the
liberal approach which favors the exercise of labor rights. The failure to observe certain
procedural requirements for a valid disaffiliation, being purely technical grounds cannot rise
above the fundamental right of self-organization. The resolution of the general membership
ratifying the disaffiliation which is initiated by the Board, substantially satisfied the procedural
requirements for disaffiliation. Settled is the rule that a local union has the right to disaffiliate
from its mother union when circumstances warrant. Generally, a labor union may disaffiliate
from the mother union to form a local or independent union only during the 60-day freedom
period immediately preceding the expiration of the CBA. However, even before the onset of the
freedom period, disaffiliation may be carried out when there is a shift of allegiance on the part
of the majority of the members of the union.

On the second issue, it is not valid for ANGLO to oust officer of SAMANA Bay. Local labor union
is separate and distinct unit primarily designated to secure and maintain an equality of
bargaining power between the employer and their employee members. A local union does not
owe its existence to the federation with which it is affiliated. It is a separate and distinct
voluntary association owing its creation to the will of its members. Mere act of affiliation does
not divest the local union of its own personality, neither does it give the mother federation the
license to act independently and without consent of the local union.