84.

ALLIANCE OF DEMOCRATIC FREE LABOR ORGANIZATION (ADFLO)

vs.UNDERSECRETARY OF LABOR BIENVENIDO LAGUESMA and CONFEDERATION OF LAB
OR AND ALLIED SOCIAL SERVICES (CLASS) G.R. No. 108625, 11 March 1996

FACTS:

The Alliance of Democratic Free Labor Organization (ADFLO) filed an application for registration as
a national federation alleging, among others that it has twelve (12) affiliates. After proper evaluation o
f its application, it was issued a Certificate of Registration to the federation.The Confederation of Lab
or and Allied Social Services (CLASS) filed a petition for the cancellation of the Registration Certificat
e issued to ADFLO.

The first hearing conducted by the BLR after the case was remanded to it for further proceedings. Ho
wever, since CLASS was not yet ready with its evidence, the hearing was postponed. CLASS then filed
its Formal Offer of Evidence. ADFLO filed an Objection to Admission of Exhibits based on the ground
s that the exhibits were not marked nor identified by any witness during the hearing of the case where
ADFLO had been properly notified. In the meantime, at the hearing of the case, CLASS failed to appea
r and only ADFLO’s President Antonio Cedilla appeared. Unaware that an objection had already been
filed by ADFLO’s counsel, Cedilla manifested that ADFLO will file its answer to CLASS’ offer of eviden
ce within thirty (30) days. BLR Director without first ruling on the admissibility of the exhibits of CLA
SS and without any further hearing then cancelled the registration of ADFLO.

ISSUE:

Whether or not a certificate of registration can be cancelled without hearing.

RULING:

Subject to the requirements of notice and due process, the registration of any legitimate labor union, c
hartered local and worker’s association may be cancelled by the Regional Director, or in the case of fe
derations, national or industry unions and trade union centers, by the Bureau Director, by filing of an
independent complaint or petition for cancellation.

The cancellation of a certificate of registration is the equivalent of snuffing out the life of a labor organ
ization. For without such registration, it loses — as a rule — its rights under the Labor Code. Under th
e circumstances, petitioner was indisputably entitled to be heard before a judgment could be rendered
cancelling its certificate of registration. In David vs. Aguilizan it was held that a decision rendered wi
thout any hearing is null and void.
85. ITOGON-SUYOC MINES, INC. vs. SANGILO-
ITOGON WORKERS’ UNION in behalf of BARTOLOME MAYO, BERNARDO AQUINO, ET AL.
G.R. No. L-24189, 30 August 1968

FACTS:

Sensing that its members were being eased out of employment one by one, Sañgilo-
Itogon Worker’s Union called a strike, accompanied by picketing carried out at or near petitioner’s mi
ne premises in Itogon. Work was paralyzed. On the fourth or fifth day of the strike, company policeme
n drove the strikers out of petitioner’s premises. The strike lasted until about 4days. Itogon contended
that Sañgilo’s registration was cancelled and therefore it has no capacity to sue.

ISSUE:

Whether or not a union which registration was cancelled cannot sue.

RULING:

No. First, Sañgilo’s registration is still valid. There is no order final in character cancelling Sañgilo’s re
gistration permit and dropping its name from the roster of legitimate labor unions. Sangilo’s status do
es not appear in the record to have changed. Therefore, Sañgilo still enjoys all the rights accorded by l
aw to a legitimate labor union. One of those rights is the right to sue.

Even assuming that Sañgilo later lost its registration permit in the course of the present proceedings,
still Sañgilo may continue as a party without need of substitution of parties, “subject however to the u
nderstanding that whatever decision may be rendered therein will only be binding upon those membe
rs of the union who have not signified their desire to withdraw from the case before its trial and decisi
on on the merits.”

The Court perceives of no reason why the judgment in favor of the fifteen individual respondent labor
ers should be overturned simply because the union of which they were members ceased to be a legitim
ate labor union. It cannot be disputed that CIR’s prosecutor brought this case not merely for Sañgilo; i
t was also on behalf of the 107 employees enumerated therein. This accounts for the fact that CIR’s jud
gment for reinstatement and backpay was rendered in favor of the fifteen respondent laborers. To acc
ept petitioner’s argument as valid is to shunt aside substance to give way to form. Error, if any, was ha
rmless. It does not affect the substantial rights of the parties in interest. It is no ground for reversal. A
t this stage this Court may even strike out Sañgilo-
Itogon Workers’ Union and leave the fifteen individual respondents alone.