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Laguna Autoparts Manufacturing Corporation vs. Sec. of Labor

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LAGUNA AUTOPARTS MANUFACTURING CORPORATION vs.

OFFICE OF THE
SECRETARY, DOLE
G.R. No. 157146 | April 29, 2005

FACTS:
Laguna Autoparts Manufacturing Corporation Obrero Pilipino-LAMCOR Chapter filed a petition
for certification election before the DOLE. It alleged that Obrero Pilipino was a legitimate labor
organization under Registration Certificate issued by DOLE. The bargaining unit sought to be
represented was composed of all the rank-and-file employees in the petitioner company, more
or less, 160 employees. It averred that the said bargaining unit is unorganized and that there
has been no certification election conducted for the past 12 months prior to the filing of the
petition.

Laguna Autoparts Mfg. Corp. moved to dismiss the petition for certification election and claimed
that the respondent union was not a legitimate labor organization for failure to show that it had
complied with the registration requirements to the Regional Office or the BLR. Further, it said
that even if the respondent union was issued a certificate of registration, it could not file a
petition for certification election since its legal personality was at question.

The Med-Arbiter dismissed the petition for certification election for lack of legal personality.

The respondent union appealed to the CA. CA reversed and set aside the order of the Med-
Arbiter and ordered for the immediate conduct of a certification election. The CA stressed that a
local or chapter need not be registered to become a legitimate labor organization. It pointed out
that a local or chapter acquires legal personality as a labor organization from the date of filing of
the complete documents.

Hece, this petition.

ISSUE: Whether or not a chapter's legal personality may be collaterally attacked in a petition for
certification election

HELD: NO. The Court ruled that such legal personality may not be subject to a collateral attack
but only through a separate action instituted particularly for the purpose of assailing it. This is
categorically prescribed by Section 5, Rule V of the Implementing Rules of Book V, which states
as follows:

SEC. 5. Effect of registration.- The labor organization or workers' association shall be


deemed registered and vested with legal personality on the date of issuance of its
certificate of registration. Such legal personality cannot thereafter be subject to collateral
attack but may be questioned only in an independent petition for cancellation in
accordance with these Rules.

Hence, to raise the issue of the respondent union's legal personality is not proper in this case.
The pronouncement of the Labor Relations Division Chief, that the respondent union acquired a
legal personality with the submission of the complete documentary requirement, cannot be
challenged in a petition for certification election.

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