Tropical Hut Employees Union-CGW v. Tropical Hut Food Market, Inc.

and NATU
[G.R. Nos. 43495-99, Jan. 20, 1990 | 181 SCRA 173]
Facts:
Rank and file workers of the Tropical Hut Food Market Incorporated organized a local union
called the Tropical Hut Employees Union. The local union was accepted for affiliation with the
National Association of Trade Unions (NATU). Following such affiliation, a Registration
Certificate was issued by the DOLE and a Collective Bargaining Agreement was concluded.
After some years, NATU received a letter from the officers of the local union informing the NATU
that the local union was disaffiliating from the NATU federation. An announcement was later
made by the local union of its new affiliation with the Confederation of General Workers (CGW).
As a result, NATU requested for the company to have the local union officers and members
suspended and then eventually dismissed from the company, alleging that they violated the
CBA.
The Arbitrator ruled in favor of the local union. This was reversed by the NLRC.
Issue: The issue is whether or not the local union can validly disaffiliate from NATU.
Held:
The local union can validly disaffiliate from NATU and be affiliated with a new federation.
The Supreme Court held that there was nothing in the CBA that forbids the local union from
disaffiliating with NATU. And more importantly, it was later on found out that NATU as a labor
federation was not registered with the Department of Labor. NATU was not even a legitimate
labor organization, and therefore did not possess and acquire, in the first place, the legal
personality to enforce its constitution and laws, much less the right and privilege under the
Labor Code to organize and affiliate chapters or locals within its group.