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Title
UST Faculty Union vs. Bitonio, Jr.

Case Ponente Decision Date

G.R. No. 131235 PANGANIBAN, J Nov 16, 1999

In a dispute over the election of o!cers in the University of Santo Tomas

Faculty Union, the Supreme Court rules against the petitioners, stating that
the election was invalid due to violations of the union's Constitution and By-
Laws, emphasizing the importance of following proper procedures and
addressing grievances in the proper forum.

Case Digest (G.R. No. 131235)

Facts:

The case involves a dispute over the election of o!cers in the University of
Santo Tomas Faculty Union (USTFU).

On October 4, 1996, a general assembly was held, attended by USTFU

members and non-members.

During this assembly, the petitioners were elected as USTFU's new set of
o!cers by acclamation and clapping of hands.

However, the election was conducted in violation of the union's Constitution

and By-Laws (CBL).

The election was not called by the USTFU and did not follow the proper
procedures outlined in the CBL.
 The respondents, who were the incumbent o!cers, "led a petition seeking
the nulli"cation of the election results.

The Bureau of Labor Relations upheld the ruling that the election was void
due to the violations of the CBL.

Issue:

Whether the public respondent, Director Bitonio, committed grave abuse of

discretion in refusing to recognize the o!cers elected during the October 4,
1996 general assembly.

Ruling:

The Supreme Court dismissed the petition.

Ratio:

The assembly held on October 4, 1996, was not a union meeting and therefore,
the election conducted during that assembly was invalid.

The election was conducted in violation of the union's Constitution and By-
Laws (CBL) as it was not called by the USTFU and did not follow the proper
procedures outlined in the CBL.

The Bureau of Labor Relations correctly ruled that the election was void due
to the violations of the CBL.

The Court emphasized the importance of following proper procedures and

addressing grievances in the proper forum.

The rati"cation of a new Collective Bargaining Agreement (CBA) did not

validate the void election.