MARIWASA SIAM CERAMICS, INC., vs.
THE SECRETARY OF THE
DEPARTMENT OF LABOR AND EMPLOYMENT, et al
G.R. No. 183317 December 21, 2009
FACTS:
On May 2005, private respondent Samahan Ng Mga Manggagawa Sa
Mariwasa Siam Ceramics, Inc. (SMMSC-Independent) was issued a
Certificate of Registration as a legitimate labor organization by the
Department of Labor and Employment (DOLE), Region IV-A.
On June 2005, petitioner Mariwasa Siam Ceramics, Inc. filed a
Petition for Cancellation of Union Registration against private
respondent, claiming that the latter violated Article 234 of the Labor
Code for not complying with the 20% requirement and that it
committed massive fraud and misrepresentation in violation of
Article 239 of the same code.
The Regional Director of DOLE IV-A issued an Order granting the
petition, revoking the registration of respondent, and delisting it
from the roster of active labor unions.
SMMSC-Independent appealed to the Bureau of Labor Relations. BLR
ruled in favor of the respondent, thus, they remain in the roster of
legitimate labor organizations.
The petitioner appealed and insisted that private respondent failed
to comply with the 20% union membership requirement for its
registration as a legitimate labor organization because of the
disaffiliation from the total number of union members of 102
employees who executed affidavits recanting their union
membership
Hence, this petition for review on certiorari under Rule 45 of the
Rules of Court.
ISSUES:
1) Whether or not there was failure to comply with the 20% union
membership requirement
2) Whether or not the withdrawal of 31 union members affected the
petition for certification election insofar as the 30% requirement is
concerned
RULING
The Supreme Court DENIED the petition.
On the first issue, while it is true that the withdrawal of support may
be considered as a resignation from the union, the fact remains that
at the time of the union’s application for registration, the affiants
were members of respondent and they comprised more than the
required 20% membership for purposes of registration as a labor
union. Article 234 of the Labor Code merely requires a 20% minimum
membership during the application for union registration. It does not
mandate that a union must maintain the 20% minimum membership
requirement all throughout its existence.
On the second issue, it appears undisputedly that the 31 union
members had withdrawn their support to the petition before the
filing of said petition. The distinction must be that withdrawals made
before the filing of the petition are presumed voluntary unless there
is convincing proof to the contrary, whereas withdrawals made after
the filing of the petition are deemed involuntary. Therefore,
following jurisprudence, the employees were not totally free from
the employer’s pressure and so the voluntariness of the employees’
execution of the affidavits becomes suspect.
The cancellation of a union’s registration doubtless has an impairing
dimension on the right of labor to self-organization. For fraud and
misrepresentation to be grounds for cancellation of union
registration under the Labor Code, the nature of the fraud and
misrepresentation must be grave and compelling enough to vitiate
the consent of a majority of union members.
Progressive development corporation-pizza hut,petitioner
v.Laguesma,Undersec of labor,&NLM defendant
Facts
NLM-Katipunan filed a petition for certification election with the
DOLE in behalf of the rank''n file employees of the progressive dev.
corp(pizza hut).Petitioners filed a motion to dismiss alleging fraud,
falsification and misrepresentation in the respondent. The motion
specifically alleged that a.) respondent union registration was tainted
with false, forged, double or multiple signatures of those who
allegedly took part in the ratification of the respondent union's
constitution and by-laws and in the election of its officers that there
were 2 sets of supposed attendees to the alleged organizational
meeting that was alleged to have taken place on june26,1993. b.)
while the application for registration of the charter was supposed to
have been approved in the organizational meeting held on much less,
c.) application for registration of the charter was supposed to have
been approved in the organizational meeting held on 1993, the
charter cert issued by the federation KATIPUNAN was dated 1993 or
1 day prior to the formation of the chapter, thus, there were serious
falsities in the dates of the issuance of the charter cert and the
organization meeting of the alleged chapter. d.) voting was not
conducted by secret ballot in violation of atr. 241,sec(c) of the labor
code (e) the constitution & by laws submitted.
Issue
Challege the legal personality of the respondent union.
Ruling
The court held that to determine the validity of labor unions art.234
requiremets of registration must be complied with. If its application
for registration is vitiated by falsification and serious
irregularities,especially those appearing on the face of the
application and the supporting documents, a labor organization
should be denied recognitin as a legitimate labor org.
Wherefore, inasmuch as the legal personality of respondent union
had been seriously challenge,it would have been more prudent to
have granted petitioners request for the suspension of proceedings
in the cert election case,until the issue of the legality of the unions
registration shall have been resolved.Failure of the med-arbiter and
public respondent to heed the request constituted a grave abuse of
discretion.
San Miguel Corp. VS Mandaue
Facts
-CA affirmes DOLE Undersecretary for Labor Relations, Rosalinda
Dimapilis-Baldoz, ordering the immediate conduct of a certification
election among the petitioner’s rank-and-file employees.
-Federation of Free Workers (FFW/ respondent) filed a petition for
certification election with the DOLE Regional Office No. VII. It sought
to be certified and to represent the permanent rank-andfile monthly
paid employees of the petitioner. The following documents were
attached to the petition: (1) a Charter Certificate certifying that
respondent as of that date was duly certified as a local or chapter of
FFW; (2) a copy of the constitution of respondent prepared by its
Secretary, Noel T. Bathan and attested by its President, Wilfred V.
Sagun; (3) a list of respondent’s officers and their respective
addresses, again prepared by Bathan and attested by Sagun; (4) a
certification signifying that respondent had just been organized and
no amount had yet been collected from its members, signed by
respondent’s treasurer Chita D. Rodriguez and attested by Sagun;
and (5) a list of all the rank-and-file monthly paid employees of the
Mandaue Packaging Products Plants and Mandaue Glass Plant
prepared by Bathan and attested by Sagun. -SMC (Petitioner) filed a
motion to dismiss the petition for certification election on the sole
ground that herein respondent is not listed or included in the roster
of legitimate labor organizations based on the certification issued by
the Officer-In representative, then right to be represented by a
bargaining agent should not be denied to other members of the
bargaining unit.”
HELD
1. NO. Ratio EFFECT NON-PARTICIPIATION PREVIOUS ELECTION. No
law, administrative rule or precedent prescribes forfeiture of the
right to vote by reason of neglect to exercise the right in past
certification elections.
2. NO. Ratio RELIGION/PAST NON-PARTICIPATION. Neither law,
administrative rule nor jurisprudence requires that only employees
affiliated with any labor organization may take part in a certification
election. On the contrary, the plainly discernible intendment of the
law is to grant the right to vote to all bona fide employees in the
bargaining unit, whether they are members of a labor organization
or not.
6.3.
CERTIFICATION ELECTIONPROCESS
1. The Union as Initiating Party ART. 212. Definitions. -(h) “Legitimate
labor organization” means any labor organization duly registered
with the Department of Labor and Employment, and includes any
branch or local thereof. Charge, Regional Director of the DOLE
Regional Office No. VII, Atty. Jesus B. Gabor.
-Respondent submitted to the Bureau of Labor Relations the same
documents earlier attached to its petition for certification. The
accompanying letter, signed by respondent’s president Sagun, stated
that such documents were submitted in compliance with the
requirements for the creation of a local/chapter pursuant to the
Labor Code and its Implementing Rules; and it was hoped that the
submissions would facilitate the listing of respondent under the
roster of legitimate labor organizations.The Chief of Labor Relations
Division of DOLE Regional Office No. VII issued a Certificate of
Creation of Local/Chapter No. ITD. I-ARFBT-058/98, certifying that
from 30 July 1998, respondent has acquired legal personality as a
labor organization/worker’s association, it having submitted all the
required documents.
San Miguel VS Laguesma
FACTS:
In the case of San Miguel Corporation Supervisors and Exempt Union
v. Laguesma, the Court held that even if they handle confidential data
regarding technical and internal business operations, supervisory
employees 3 and 4 and the exempt employees of petitioner San
Miguel Foods, Inc. are not to be considered confidential employees,
because the same do not pertain to labor relations, particularly,
negotiation and settlement of grievances. Consequently, they were
allowed to form an appropriate bargaining unit for the purpose of
collective bargaining. The Court also declared that the employees
belonging to the three different plants of San Miguel Corporation
Magnolia Poultry Products Plants in Cabuyao, San Fernando, and Otis,
having community or mutuality of interests, constitute a single
bargaining unit.
A certification election was conducted. On the date of the election,
petitioner filed the Omnibus Objections and Challenge to Voters,
questioning the eligibility to vote by some of its employees on the
grounds that some employees do not belong to the bargaining unit
which respondent seeks to represent or that there is no existence of
employer-employee relationship with petitioner.
Based on the results of the election, the Med-Arbiter issued the
Order stating that since the Yes vote received 97% of the valid votes
cast, respondent is certified to be the exclusive bargaining agent of
the supervisors and exempt employees of petitioner's Magnolia
Poultry Products Plants in Cabuyao, San Fernando, and Otis.
On appeal, the then Acting DOLE Undersecretary, in the Resolution,
affirmed the Order of the Med-Arbiter.
CA affirmed the Resolution of DOLE Undersecretary with
modification stating that those holding the positions of Human
Resource Assistant and Personnel Assistant are excluded from the
bargaining unit.
Hence, this petition by the San Miguel Foods
ISSUE: W/N CA departed from jurisprudence when it expanded the
scope of the bargaining unit.
RULING: No. In San Miguel vs Laguesma, the Court explained that the
employees of San Miguel Corporation Magnolia Poultry Products
Plants of Cabuyao, San Fernando, and Otis constitute a single
bargaining unit, which is not contrary to the one-company, one-union
policy. An appropriate bargaining unit is defined as a group of
employees of a given employer, comprised of all or less than all of
the entire body of employees, which the collective interest of all the
employees, consistent with equity to the employer, indicate to be
best suited to serve the reciprocal rights and duties of the parties
under the collective bargaining provisions of the law.
It held that while the existence of a bargaining history is a factor that
may be reckoned with in determining the appropriate bargaining unit,
the same is not decisive or conclusive. Other factors must be
considered. The test of grouping is community or mutuality of
interest. This is so because the basic test of an asserted bargaining
unit’s acceptability is whether or not it is fundamentally the
combination which will best assure to all employees the exercise of
their collective bargaining rights. Certainly, there is a mutuality of
interest among the employees. Their functions mesh with one
another. One group needs the other in the same way that the
company needs them both. There may be differences as to the nature
of their individual assignments, but the distinctions are not enough
to warrant the formation of a separate bargaining unit.
The Court affirms the finding of the CA that there should be only one
bargaining unit for the employees in Cabuyao, San Fernando, and
Otis of Magnolia Poultry Products Plant involved in dressed chicken
processing and Magnolia Poultry Farms engaged in live chicken
operations. Certain factors, such as specific line of work, working
conditions, location of work, mode of compensation, and other
relevant conditions do not affect or impede their commonality of
interest. Although they seem separate and distinct from each other,
the specific tasks of each division are actually interrelated and there
exists mutuality of interests which warrants the formation of a single
bargaining unit.
Acedera v International Container Services
FACTS:
Jerry Acedera, et al. are employees of International Container
Terminal Services, Inc. (ICTSI) and are members of Associated Port
Checkers & Workers Union-International Container Terminal Services,
Inc.(APCWU-ICTSI), a duly registered labor organization. ICTSI
entered into a five-year Collective Bargaining Agreement (CBA) with
APCWU which reduced the employees· work days from 304 to 250
days a year.
The Wage Board decreed wage increases in NCR which affected ICTSI.
Upon the request of APCWU to compute the actual monthly increase
in the employee’s salary by multiplying the mandated increase by
365days and dividing by12 months, ICTSI stopped using 304 days as
divisor and started using 365 days to determine the daily wage.
Later on, ICTSI entered into a retrenchment program which
prompted APCWU to file a complaint before the Labor Arbiter (LA)
for ICTSI·s use of 365 days, instead of 250 days, as divisor in the
computation of wages. Acedera et al. filed a Motion to Intervene
which was denied by the LA. On appeal, National Labor Relations
Commission (NLRC) affirmed LA·s decision. Acedera et al. filed a
petition for certiorari to the Court of Appeals (CA) which was
dismissed.
LA: denied motion to intervene
NLRC: affirmed LA’s decision
CA: dismissed appeal
ISSUE/S:
1. Whether or not Acedera et al. have no legal right to intervene in
the case as their intervention was a superfluity
RULING: YES, there is unfair labor practice.
1. That APCWUacted in a representative capacity "for and in behalf
of its Union members and other employees similarly situated, the
title of the case filed by it at the Labor Arbiters Office so expressly
states. While a party acting in a representative capacity, such as a
union, may be permitted to intervene in a case, ordinarily, a person
whose interests are already represented will not be permitted to do
the same except when there is a suggestion of fraud or collusion or
that there representative will not act in good faith for the protection
of all interests represented by him.
2. Acedera et al. cite the dismissal of the case filed by ICTSI, first by
the Labor Arbiter, and later by the Court of Appeals. The dismissal of
the case does not, however, by itself show the existence of fraud or
collusion or a lack of good faith on the part of APCWU.
3. There must be clear and convincing evidence of fraud or collusion
o lack of good faith independently of the dismissal. This, Acedera et
al. failed to proffer. Acedera et al. likewise express their fear that
APCWU would not prosecute the case diligently because of its
“sweetheart relationship" with ICTSI. There is nothing on record,
however, to support this alleged relationship which allegation
surfaces a a mereafterthought because it was never raised early on.
It was raised only in petitioners-appellants· reply to ICTSI’s comment
in the petition at bar, the last pleading submitted to this Court, which
was filed on June 20, 2001 or more than 42 months after petitioners-
Appellants filed their Complaint-in-Intervention with Motion to
Intervene with the Labor Arbiter.
To reiterate, for a member of a class to be permitted to intervene in
a representative action, fraud or collusion or lack of good faith on the
part of the representative must be proven. It must be based on facts
borne on record.
Mere assertions, as what petitioners-appellants proffer, do not
suffice.
Minette Baptista v Rosario Villanueva
FACTS:
Petitioners and other members of the union filed impeachment
complaint against all the union officers and members of RPNEU and
audit before the DOLE for suspicion of union mismanagement.
Thereafter, complaints, were filed against petitioners and several
others for alleged violation of the union’s Constitution and By-Laws
and violation of Section 2.5 of Article IX for urging or advocating that
a member start an action in any court of justice or external
investigative body against the Union or its officer without first
exhausting all internal remedies open to him or available in
accordance with the CBL. Petitioners and their group denied the
charges imputed against them and contested the procedure adopted
by the Committee in its investigation.
The Committee submitted their recommendation of expulsion from
the union to RPNEU’s Board of Directors which the latter affirmed
and they were served expulsion notice. And their employment was
terminated in compliance with their CBA’s union security clause.
Petitioners filed complaints for ULP against the respondents
questioning legality of their expulsion from the union and their
subsequent termination from employment. LA ruled in favor of the
petitioners and adjudged the respondents guilty of ULP pursuant to
Article 249 (a) and (b) of the Labor Code. NLRC, on appeal, dismissed
the case for lack of merit. CA sustained the NLRC Decision.
ISSUE: Whether or not the labor organization is guilty of unfair labor
practice when it expels members pursuant to the Union’s CBL.
RULING: No. It is well-settled that workers’ and employers’
organizations shall have the right to draw up their constitutions and
rules to elect their representatives in full freedom, to organize their
administration and activities and to formulate their programs. In this
case, RPNEU’s Constitution and By-Laws expressly mandate that
before a party is allowed to seek the intervention of the court, it is a
pre-condition that he should have availed of all the internal remedies
within the organization. Petitioners were found to have violated the
provisions of the union’s Constitution and By-Laws when they filed
petitions for impeachment against their union officers and for audit
before the DOLE without first exhausting all internal remedies
available within their organization. This act is a ground for expulsion
from union membership. Thus, petitioners’ expulsion from the union
was not a deliberate attempt to curtail or restrict their right to
organize, but was triggered by the commission of an act, expressly
sanctioned by the union’s Constitution and By-Laws.
Unfortunately, petitioners failed to discharge the burden required to
prove the charge of ULP against the respondents. Aside from their
self-serving allegations, petitioners were not able to establish how
they were restrained or coerced by their union in a way that curtailed
their right to self-organization. The records likewise failed to
sufficiently show that the respondents unduly persuaded
management into discriminating against petitioners. other than to
bring to its attention their expulsion from the union, which in turn,
resulted in the implementation of their CBA’ s union security clause.
As earlier stated, petitioners had the burden of adducing substantial
evidence to support its allegations of ULP, which burden they failed
to discharge. In fact, both the NLRC and the CA found that petitioners
were unable to prove their charge of ULP against the respondents.
THE HERITAGE HOTEL MANILA (OWNED AND OPERATED BY GRAND
PLAZA HOTEL CORPORATION) vs. PINAG-ISANG GALING AT LAKAS NG
MGA MANGGAGAWA SA HERITAGE MANILA (PIGLAS-HERITAGE)
G.R. No. 177024, October 30, 2009

Abad, J.:
DOCTRINES: The Labor Code and its implementing rules do not
require that the number of members appearing on the documents in
question should completely dovetail. For as long as the documents
and signatures are shown to be genuine and regular and the
constitution and by-laws democratically ratified, the union is deemed
to have complied with registration requirements.
Labor laws are liberally construed in favor of labor especially
if doing so would affirm its constitutionally guaranteed right to self-
organization.
The right of any person to join an organization also includes
the right to leave that organization and join another one.
FACTS: The Heritage Hotel Employees Union (HHE) was formed in
2000 by certain rank and file employees of herein petitioner Heritage
Hotel Manila, to which the Department of Labor and Employment-
National Capital Region issued a certificate of registration. HHE filed
a petition for certification election which petitioner opposed on the
ground that HHE misrepresented itself to be an independent union,
when in fact it was a local chapter of the National Union of Workers
in Hotel and Restaurant and Allied Industries (NUWHRAIN). It was
also alleged that such omitted disclosure was intentional because
petitioner’s supervisors union was already affiliated with it.
Petitioner also filed a petition to cancel the union’s registration
certificate. The Med-Arbiter nevertheless granted HHE’s petition for
certification election.
Petitioner appealed to the Secretary of Labor but it was denied as
well as its motion for reconsideration, prompting petitioner to file a
petition for certiorari with the Court of Appeals. The CA issued a writ
of injunction against the holding of HHE’s certification election until
the petition for cancellation of its registration shall have been
resolved with finality.
In 2003, another union, herein respondent Pinag-Isang
Galing at Lakas ng mga Manggagawa sa Heritage Manila (PIGLAS),
was formed by certain rank and file employees of petitioner at a
meeting. PIGLAS was issued its registration certificate by the DOLE-
NCR in 2004. HHE later on adopted a resolution for its dissolution and
then filed a petition for cancellation of its union registration.
PIGLAS filed a petition for certification election which
petitioner opposed alleging that the new union’s officers and
members were also those who comprised the old union. Petitioner
likewise alleged that PIGLAS was formed to circumvent the CA’s
injunction earlier issued. The Med-Arbiter nevertheless granted the
petition for certification election.
Petitioner filed a petition to cancel PIGLAS’ registration,
claiming that the documents submitted with the union’s application
for registration bore the following false information:
(a) The List of Members showed that the PIGLAS union had 100 union
members;
(b) The Organizational Minutes said that 90 employees attended the
meeting on
December 10, 2003;
(c) The Attendance Sheet of the meeting of December 10, 2003 bore
the signature of
127 members who ratified the union’s Constitution and By-Laws; and
(d) The Signature Sheet bore 128 signatures of those who attended
that meeting.
Petitioner alleged that the misrepresentation was evidenced
by the discrepancy in the number of union members appearing in the
application and the list as well as the number of signatories to the
attendance and signature sheets. The minutes reported only 90
employees attended the meeting. Petitioner also alleged that 33
members of PIGLAS were members of HHE, which is in violation of
the policy against dual unionism.
DOLE-NCR denied petitioner’s petition to cancel PIGLAS’
registration because the discrepancies in the number of members in
the application’s supporting documents were not material and did
not constitute misrepresentation. The dual unionism is also not a
ground for canceling registration, since the members of HHE simply
exercised their right to self-organization and freedom of association
when they joined PIGLAS. The Bureau of Labor Relations affirmed the
DOLE-NCR, by reasoning that PIGLAS’ organization meeting lasted for
12 hours. Thus, it was possible for the number of attendees to have
increased as the meeting progressed. Besides, the union only needed
50 members of the total of 250 employees in the bargaining unit to
comply with the 20% membership requirement. Petitioner filed a
petition for certiorari with the Court of Appeals but it was denied as
well as petitioner’s motion for reconsideration. Hence, this petition
for review under Rule 45.
ISSUES: (1) Whether or not the union made fatal misrepresentation
in its application for union registration
(2) Whether or not dual unionism is a ground for canceling a union’s
registration.
HELD: (1) NO. Petitioner has no evidence of the alleged
misrepresentation. The discrepancies alone cannot be taken as
indication that PIGLAS misrepresented the information contained in
these documents. Charges of fraud and misrepresentation should be
clearly established by evidence and surrounding circumstances
because once it is proved, the labor union acquires none of the rights
accorded to registered organizations.
The discrepancies can be explained. While it appears that in
the minutes of the December 10, 2003 organizational meeting, only
90 employees responded to the roll call at the beginning, it cannot be
assumed that such number could not grow to 128 as reflected on the
signature sheet for attendance. The meeting lasted 12 hours from
11:00am to 11:00pm. There is no evidence that the meeting hall was
locked up to exclude late attendees. As to the fact that only 127
members ratified the union’s constitution and by-laws when 128
signed the attendance sheet, it cannot be assumed that all those who
attended approved of such. Any member had the right to hold out
and refrain from ratifying those documents or to simply ignore the
process. The Labor Code and its implementing rules do not require
that the number of members appearing on the documents in
question should completely dovetail. For as long as the documents
and signatures are shown to be genuine and regular and the
constitution and by-laws democratically ratified, the union is deemed
to have complied with registration requirements.
The discrepancy in the list of members (showing only 100
members) and the signature and attendance sheets (showing 127 or
128 members) submitted is immaterial. A comparison of the
documents shows that except for six members, the names found in
the list are also in the attendance and signature sheets. PIGLAS more
than complied with the 20% requirement since only 50 employees
out of 250 employees in the bargaining unit were required to
unionize.
Labor laws are liberally construed in favor of labor especially
if doing so would affirm its constitutionally guaranteed right to self-
organization. PIGLAS union’s supporting documents reveal the
unmistakable yearning of petitioner company’s rank and file
employees to organize. This yearning should not be frustrated by
inconsequential technicalities.
(2) NO. The right of any person to join an organization also includes
the right to leave that organization and join another one. HHE union
ceased to exist, its certificate of registration being already cancelled.
The Heritage Hotel Manila v NUWHRAIN-HHMSC
ACTS:
The respondent’s petition for certification election was granted.
Petitioner then discovered that respondent had failed to submit to
the Bureau of Labor Relations (BLR) its annual financial report for
several years and the list of its members since it filed its registration
papers in 1995. Consequently, it filed a Petition for Cancellation of
Registration of respondent, on the ground of the non-submission of
the said documents. Petitioner prayed that respondent’s Certificate
of Creation of Local/Chapter be cancelled and its name be deleted
from the list of legitimate labor organizations. It further requested
the suspension of the certification election proceedings.
Nevertheless, the certification election pushed through and the
respondent won.
right and privileges granted by law to a legitimate labor organization,
particularly the right to participate in or ask for certification election
in a bargaining unit. Thus, the cancellation of a certificate of
registration is the equivalent of snuffing out the life of a labor
organization. For without such registration, it loses – as a rule – its
rights under the Labor Code.

The Regional Director of DOLE-NCR and DOLE Secretary both held

that constitutionally guaranteed freedom of association and right of Furthermore, that the Labor Code’s provisions on cancellation of
workers to self-organization outweighed respondent’s union registration and on reportorial requirements have been
noncompliance with the statutory requirements to maintain its recently amended by Republic Act (R.A.) No. 9481, An Act
status as a legitimate labor organization. Strengthening the Workers’ Constitutional Right to Self-Organization,
Amending for the Purpose Presidential Decree No. 442, As Amended,
ISSUE: Otherwise Known as the Labor Code of the Philippines, which says
that failure to file financial reports and list of union members shall
Whether or not the failure to comply with the statutory not be a ground for cancellation of union registration but shall
requirement(filing financial reports and the list of its members) subject the erring officers or members to suspension, expulsion from
sufficient ground for the cancellation of registration of the membership, or any appropriate penalty.
respondent as a labor union.

HELD:

No, the non-compliance should not be a ground for the cancellation.

Articles 238 and 239 of the Labor Code provide that failure to file
financial reports and the list of its members are grounds for the
cancellation of Union Organization. However, consideration must be
taken of the fundamental rights guaranteed by Article XIII, Section 3
of the Constitution, i.e., the rights of all workers to self-organization,
collective bargaining and negotiations, and peaceful concerted
activities. Labor authorities should bear in mind that registration
confers upon a union the status of legitimacy and the concomitant