181 Confederation of Citizens Labor Union v.

NLRC
G.R. Nos. L-38955-56 (October 31, 1974)

Facts: There are 2 consolidated cases in this decision both with the same issue.

Continental Manufacturing Corporation (CMC) renewed for another three years its CBA with
Continental Employees and Labors Association (CELA) on February 15, 1974. Respondent
Federation of Free Workers filed a petition for certification election 3 days prior to the renewal
of CBA.

Redson Textile Manufacturing Company signed on March 4, 1974 a CBA with Redson Employees
and Laborers Association (RELA) but to be effective as of February 16, 1974. FFW filed a petition
for certification election on February 25, 1974.

Both CMC and Redson filed a petition to dismiss the certification election citing that it was bared
by the SBA they signed. NLRC granted the petitions and directed the Bureau of Labor Relations
to conduct the certification elections.

Issue: WON contract-bar rule will apply

Held: No. The contract-bar rule is a principle in labor law that a collective bargaining agreement
of reasonable duration is in the interest of the stability of industrial relations, a bar to certification
elections. During the life of a certified CBA, the NLRC shall not entertain any representation issues
which may in any manner affect the administration of the agreement.

A petition may be filed within 60 days before its expiration date. In the absence of a CBA, petition
may be filed at any time.