RAQUEL CANDELARIA JD2B /+63917-717-5119

CASE #9
THE HERITAGE HOTEL MANILA vs. NATIONAL UNION OF WORKERS (NUWHRAIN-
HHMSC), G.R. No. 178296, January 12, 2011

ISSUE: Does the negligence of union officers to submit its annual reports and list of individual
members in accordance with Article 239 of the Labor Code should lead to the
cancellation of union registration?

SC RULING: No, it should not lead to cancellation of union registration.

RATIO: “As aptly ruled by respondent Bureau of Labor Relations Director Noriel: "The
rights of workers to self-organization finds general and specific constitutional guarantees.
Such constitutional guarantees should not be lightly taken much less nullified. A healthy
respect for the freedom of association demands that acts imputable to officers or members
be not easily visited with capital punishments against the association itself."

The Supreme Court ruled that “an overly stringent interpretation of the statute governing
cancellation of union registration without regard to surrounding circumstances cannot be
allowed. Otherwise, it would lead to an unconstitutional application of the statute and
emasculation of public policy objectives. Worse, it can render nugatory the protection to
labor and social justice clauses that pervades the Constitution and the Labor Code.”

INSTRUCTION LEARNED: That the cancellation of certificate of registration of a labor

organization is equivalent of snuffing out of its life. Without such registration, the
labor organization loses its rights under the Labor Code.
-------------------------------------------oOo-----------------------------------------