Statutory Construction

PAFLU vs. Bureau of Labor Relations

August 21, 1976
FERNANDO, Acting CJ
FACTS:
Petitioner Philippine Association of Free Labor Unions (PAFLU) lost
against the National Federation of Free Labor Unions (NAFLU) as the
exclusive bargaining agent of all the employees in the Philippine Blooming
Mills, Co., Inc. NAFLU won by 429 votes against 414 votes for PAFLU.
Petitioner argues that spoiled ballots should be counted pursuant to the
doctrine announced in the case of Allied Workers Association of the
Philippines vs. Court of Industrial Relations.
ISSUE/S:
1 W/N the spoiled ballots should be counted.
HELD:
1 No. The doctrine in the said case arose during the period when the law
in effect was the Industrial Peace Act. The Industrial Peace Act was
replaced by the Labor Code on November 1, 1974. According to the
rules of the Labor Code, only valid votes should be considered and
counted.

Notes:
1 Petition is dismissed.