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CONSTI Case Digest - ACCFA Vs CUGCO

The Agricultural Credit and Cooperative Financing Administration (ACCFA) appealed a decision of the Court of Industrial Relations regarding unfair labor practice complaints filed by ACCFA unions. The ACCFA argued it did not have governmental functions and thus the labor disputes were not under the CIR's jurisdiction. The Supreme Court ruled that ACCFA exercised governmental functions through its role in implementing the Philippine government's land reform program. It was placed under the Land Reform Project Administration along with other government agencies. The Court found that under Republic Act No. 3844, the ACCFA's successor agency, the Agricultural Credit Administration, was clearly a government office, and its personnel were subject to Civil Service rules. Therefore, the CIR properly exercised jurisdiction over the labor disputes.

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110 views2 pages

CONSTI Case Digest - ACCFA Vs CUGCO

The Agricultural Credit and Cooperative Financing Administration (ACCFA) appealed a decision of the Court of Industrial Relations regarding unfair labor practice complaints filed by ACCFA unions. The ACCFA argued it did not have governmental functions and thus the labor disputes were not under the CIR's jurisdiction. The Supreme Court ruled that ACCFA exercised governmental functions through its role in implementing the Philippine government's land reform program. It was placed under the Land Reform Project Administration along with other government agencies. The Court found that under Republic Act No. 3844, the ACCFA's successor agency, the Agricultural Credit Administration, was clearly a government office, and its personnel were subject to Civil Service rules. Therefore, the CIR properly exercised jurisdiction over the labor disputes.

Uploaded by

Johñ Lewis Ferrer
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No.

L-21484          November 29, 1969

THE AGRICULTURAL CREDIT and COOPERATIVE FINANCING ADMINISTRATION


(ACCFA), petitioner,
vs.
ACCFA SUPERVISORS' ASSOCIATION, ACCFA WORKERS' ASSOCIATION, and THE COURT OF
INDUSTRIAL RELATIONS, respondents.

Facts

These are two separate appeals by certiorari from the decision dated March 25, 1963 (G.R. No.
L-21484) and the order dated May 21, 1964 (G.R. No. L-23605) as affirmed by the
resolutions en banc, of the Court of Industrial Relations, in Cases Nos. 3450-ULP and 1327-MC,
respectively. The parties, except the Confederation of Unions in Government Corporations and
Offices (CUGCO), being practically the same and the principal issues involved related, only one
decision is now rendered in these two cases.

The Agricultural Credit and Cooperative Financing Administration (ACCFA) was a government
agency created under Republic Act No. 821, as amended. Its administrative machinery was
reorganized and its name changed to Agricultural Credit Administration (ACA) under the Land
Reform Code (Republic Act No. 3844). On the other hand, the ACCFA Supervisors' Association
(ASA) and the ACCFA Workers' Association (AWA), hereinafter referred to as the Unions, are
labor organizations composed of the supervisors and the rank-and-file employees, respectively,
in the ACCFA (now ACA).

The Unions and the ACCFA entered into a collective bargaining agreement, which was to be
effective for a period of one (1) year. A few months thereafter, the Unions, together with the
Confederation of Unions in Government Corporations and Offices (CUGCO), filed a complaint
with the Court of Industrial Relations (CIR) against the ACCFA (Case No. 3450-ULP) 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. The ACCFA denied the charges and interposed as affirmative and special defenses
lack of jurisdiction of the CIR over the case, illegality of the bargaining contract, expiration of
said contract and lack of approval by the office of the President of the fringe benefits provided
for therein. Brushing aside the foregoing defenses, The CIR in its decision ordered the ACCFA, to
cease and desist from committing further acts tending to discourage the members of
complainant unions in the exercise of their right to self-organization; to comply with and
implement the provision of the collective bargaining contract executed on September 4, 1961,
including the payment of P30.00 a month living allowance; and to bargain in good faith and
expeditiously with the herein complainants.

The ACCFA moved to reconsider but was turned down. Thereupon, it brought this appeal
by certiorari.
Issue
Whether the Agricultural Credit and Cooperative Financing Administration (ACCFA) exercised
governmental functions.
Ruling
Yes. ACCFA exercised governmental functions.
According to Republic Act No. 3844, the implementation of the Land Reform Program of the
government is most certainly a governmental, not a proprietary, function; and for that purpose
Executive Order No. 75 has placed the Agricultural Credit Administration (ACA) under the Land
Reform Project Administration together with the other member agencies, the personnel
complement of all of which are placed in one single pool and made available for assignment
from one agency to another, subject only to Civil Service laws, rules and regulations, position
classification and wage structures.
The law itself declares that the ACA is a government office, with the formulation of policies,
plans and programs vested no longer in a Board of Governors, as in the case of the ACCFA, but
in the National Land Reform Council, itself a government instrumentality; and that its personnel
are subject to Civil Service laws and to rules of standardization with respect to positions and
salaries, any vestige of doubt as to the governmental character of its functions disappears.

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