ACCFA vs.

ACCFA SUPERVISORS' ASSOCIATION, ACCFA WORKERS' ASSOCIATION, and THE COURT OF

INDUSTRIAL RELATIONS
G.R. No. L-21484

Facts:
A CBA was entered into by and between the Unions and the ACCFA. A few months thereafter, the
Unions started protesting against alleged violations and non-implementation of said agreement. Finally,
the Unions declared a strike, which was ended when the strikers voluntarily returned to work. The
Unions, together with its mother union, filed a complaint with the Court of Industrial Relations against
the ACCFA for having allegedly committed acts of unfair labor practice, namely: violation of the
collective bargaining agreement in order to discourage the members of the Unions in the exercise of
their right to self-organization, discrimination against said members in the matter of promotions, and
refusal to bargain.
ACCFA moved for a reconsideration but while the appeal was pending, RA 3844 was passed which
effectively turned ACCFA to ACA. Then, ASA and AWA petitioned that they obtain sole bargaining rights
with ACA. While this petition was not yet decided upon, EO 75 was also passed which placed ACA under
the Land Reform Project Administration. Notwithstanding the latest legislation passed, the trial court
and the appellate court ruled in favor of ASA and AWA.

Issue:
Whether or not ACA is a government entity

Ruling:
Yes. The Unions have no bargaining rights with ACA. EO 75 placed ACA under the LRPA and by virtue of
RA 3844 the implementation of the Land Reform Program of the government is a governmental function
NOT a proprietary function. Being such, ACA can no longer step down to deal privately with said unions
as it may have been doing when it was still ACCFA. However, the growing complexities of modern
society have rendered the classification of the governmental functions as unrealistic, if not obsolete.
Ministerial and governmental functions continue to lose their well-defined boundaries and are absorbed
within the activities that the government must undertake in its sovereign capacity if it to meet the
increasing social challenges of the times and move towards a greater socialization of economic forces.
Hence, no further fringe benefits may be demanded on the basis of any collective bargaining agreement.
The decisions and orders appealed from are set aside and/or modified in accordance with the foregoing
pronouncements. No costs.