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The Supreme Court ruled that the Court of Industrial Relations (CIR) has the authority to investigate alleged violations of internal labor organization procedures and require the production of relevant documents. The complainants alleged unauthorized disbursement of union funds and failure to provide financial reports by the union leaders. The CIR ordered the leaders to produce financial records rather than grant an injunction. The Court found this was within the CIR's statutory power to investigate such matters and ensure compliance with laws protecting union members.
The Supreme Court ruled that the Court of Industrial Relations (CIR) has the authority to investigate alleged violations of internal labor organization procedures and require the production of relevant documents. The complainants alleged unauthorized disbursement of union funds and failure to provide financial reports by the union leaders. The CIR ordered the leaders to produce financial records rather than grant an injunction. The Court found this was within the CIR's statutory power to investigate such matters and ensure compliance with laws protecting union members.
The Supreme Court ruled that the Court of Industrial Relations (CIR) has the authority to investigate alleged violations of internal labor organization procedures and require the production of relevant documents. The complainants alleged unauthorized disbursement of union funds and failure to provide financial reports by the union leaders. The CIR ordered the leaders to produce financial records rather than grant an injunction. The Court found this was within the CIR's statutory power to investigate such matters and ensure compliance with laws protecting union members.
Tabaniag et al. The Supreme Court ruled that the power of respondent court to assure compliance with internal labor organization procedures with the authority to investigate to substantiate Facts: alleged violations may be found in paragraphs (b), (h), and (1) Section 17 of The principal complainants in the complaint the Industrial Peace Act.1 filed by the prosecution division of Court of Industrial Relations (CIR) against Pablo The complaint before the CIR recited an Catura and Luz Salvador, Treasurer and unauthorized disbursement of union funds President, respectively, were herein as well as failure to make full and detailed respondents Celestino and the other report of financial transactions of the union. members of the Philippine Virginia Tobacco Clearly, the matter was deemed serious Administration Employees Asssociation, a enough to call for the exercise of the legitimate labor organization. Catura and statutory power of investigation to Salvador were alleged to have been substantiate the alleged violation so as to responsible for unauthorized disbursement assure that the rights and conditions of of union funds. The complainants tried to membership in a labor organization as set settle their issue exhausting all remedies forth in the said Section be respected. provided for in the unions constitution and by-laws to no avail. All the challenged order did was to require petitioners to deliver and deposit the Celestino and the other complainants relevant documents. It cannot be said that sought before the court an injunction to such a requirement is beyond the statutory prevent Catura from taking his oath of office power conferred. The authority to because of his refusal to make a full and investigate might be rendered futile if detailed report of all financial transactions of respondent court could be held as having the union. Instead of granting an injunction, acted contrary to law. the CIR limited itself to requiring and directing Catura and Salvador to deliver and The power to investigate, requires an deposit to the court all the book of accounts, inquiry into existing facts and conditions. bank accounts, pass books of the The documents required to be produced Association and other related documents. constitutes evidence of the most solid character as to whether or not there was a Now petitioner challenges the order issued on the ground that respondent court does 1 not possess any power to issue the same. "The members shall be entitled to full and detailed reports from their officers and representatives of all financial transactions as provided in the constitution and by-laws of the organization." Issue: . . . "The funds of the organization shall not be Whether the order issued by the judge was applied for any purpose or object other than those proper. expressly stated in its constitution or by-laws or those expressly authorized by a resolution of the majority of the member."
. . . "The books of accounts and other records of the
financial activities of a legitimate labor organization shall be open to inspection by any official or member thereof." failure to comply with the mandates of the law. It is not for this Court to whittle down the authority conferred on administrative agencies to assure the effective administration of a statute, in this case intended to protect the rights of union members against its officers. The matter was properly within its cognizance and the means necessary to give it force and effectiveness should be deemed implied unless the power sought to be exercised is so arbitrary as to trench upon private rights of petitioners entitled to priority. No such showing has been made.