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Title
Holy Child Catholic School vs. Sto. Tomas

Case Ponente Decision Date

G.R. No. 179146 PERALTA, J Jul 23, 2013

The case of Holy Child Catholic School v. Sto. Tomas explores the
legitimacy of a labor organization's right to !le a petition for certi!cation
election despite the commingling of supervisory and rank-and-!le
employees, ultimately a"rming that the determination of an appropriate
bargaining unit should be based on the commonality or mutuality of
interest among the employees.

Case Digest (G.R. No. 179146)

Facts:

The case involves a petition for review on certiorari under Rule 45 of the
Supreme Court.

The petitioner is Pinag-Isang Tinig at Lakas ng Anakpawis Holy Child

Catholic School Teachers and Employees Labor Union (HCCS-TELU-
PIGLAS).

The respondent is Holy Child Catholic School (HCCS).

On May 31, 2002, HCCS-TELU-PIGLAS !led a petition for certi!cation

election, claiming to be a legitimate labor organization duly registered with
the Department of Labor and Employment (DOLE).

HCCS argued that the proposed bargaining unit was inappropriate as it

consisted of a mixture of managerial, supervisory, and rank-and-!le
employees, as well as teaching and non-teaching personnel.
 The Med-Arbiter initially denied the petition, but the Secretary of the
Department of Labor and Employment (SOLE) reversed the decision and
ordered the conduct of separate certi!cation elections for teaching and
non-teaching personnel.

Issue:

Whether the commingling of supervisory and rank-and-!le employees in

one labor organization a#ects its legitimacy or right to !le a petition for
certi!cation election.

Ruling:

The commingling does not a#ect the legitimacy or right of the labor
organization to !le a petition.

Ratio:

The Court cited previous cases that established the principle that the
commingling of supervisory and rank-and-!le employees in a labor
organization does not automatically invalidate the organization.

The determination of an appropriate bargaining unit should be based on

the commonality or mutuality of interest among the employees.

In this case, the Court found that the teaching and non-teaching personnel
have distinct interests and working conditions, warranting the formation
of separate bargaining units.

Conclusion:

The Supreme Court a"rmed the decision of the Secretary of Labor to

conduct separate certi!cation elections for teaching and non-teaching
personnel.

The commingling of supervisory and rank-and-!le employees in one labor

organization does not a#ect its legitimacy or right to !le a petition.

The commonality or mutuality of interest among employees should be

considered in determining the appropriate bargaining unit.