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De La Salle University v. De La Salle University Employees Association (DLSUEA-NAFTEU) G.R. No.

177283, April 7, 2009 Facts : In 2001, a splinter group of respondent filed a petition for conduct of elections with the DOLE alleging that the then incumbent officers of respondent had failed to call for a regular election since 1985. Respondents officers claimed that by virtue of RA 6715, which amended the Labor Code, the term of office of its officers was extended to five years or until 1992 during which a general assembly was held affirming their hold-over tenure until the termination of collective bargaining negotiations. Acting on the petitioner, the DOLE-NCR held that the holdover authority of respondents incumbent set of officers had been extinguished by virtue of the execution of the CBA and ordered the conduct of elections subject to pre-election conferences. Respondent wrote a letter to DLSU President to put on escrow all union dues/agency fees and whatever money considerations deducted from salaries of concerned co-academic personnel until the election of union officials has been scheduled and been held. Petitioner in response, to do the following: (1) establish a savings account for the Union where all collected union dues and agency will be deposited and held in trust; and (2) discontinue normal relations with any group within the Union including the incumbent set of officers. Respondents filed a complaint against petitioner for Unfair Labor Practice (ULP) claiming that petitioner unduly interfered with its internal affairs. During the pendency of this complaint, respondent file a notice of strike. LA dismissed the respondent ULP complaint. On appeal, NLRC affirmed the decision of LA. On respondents petition for certiorari before the CA, the Court set aside the decision of NLRC. Hence, petitioners petition for review on certiorari. Issue: Whether the NLRC gravely abuse its discretion when it held that petitioner were not guilty of ULP considering that the temporary measures implemented by the University were undertaken in good faith and only to maintain its neutrality amid the intra-union dispute. Ruling: It bears noting that at the time petitioners questioned moves were adopted, a valid and existing CBA had been entered between the parties. It thus behooved petitioners to observe the terms and conditions thereof bearing on union dues and representation. It is axiomatic in labor relations that a CBA entered into by a legitimate labor organization and an employer become the law between the parties, compliance with which is mandated by express policy of the law.

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