G.R. No. L-35252 November 29, 1972
LIBERTY MANUFACTURING WORKERS UNION, petitioner, vs. THE COURT OF FIRST INSTANCE OF BULACAN, 5th JUDICIAL DISTRICT, AND THE LIBERTY MANUFACTURING CORPORATION, respondents.

FACTS

The Liberty Manufacturing Workers Union filed a single complaint in the Court of First Instance of Bulacan on behalf of fifty-seven (57) of its members. The union alleged that these rank-and-file employees were illegally terminated by the Liberty Manufacturing Corporation effective December 31, 1971, without the requisite notice. The complaint sought to recover termination pay for each named employee, with individual claims ranging from P221.00 to P750.75, aggregating to a total sum of P22,189.25, plus damages and attorney’s fees. The respondent corporation moved to dismiss the complaint on two grounds: first, that the court lacked jurisdiction because the individual claims did not exceed P10,000.00, and second, that the labor union was not the real party in interest.
The respondent court granted the motion to dismiss. It ruled that since the claim was based on a provision of law (presumably regarding termination pay) and not on a collective bargaining agreement, the real parties in interest were the individual employees, not the union. Furthermore, it held that because each individual claim was below P10,000.00, the court lacked jurisdiction over the subject matter. The union appealed this dismissal order directly to the Supreme Court.

ISSUE

The primary issues are: (1) Whether the petitioner union has the legal capacity and interest to file a representative suit to recover termination pay on behalf of its individual members; and (2) Whether the Court of First Instance has jurisdiction over the complaint based on the aggregate sum of the claims (P22,189.25) despite each individual claim being less than P10,000.00.

RULING

The Supreme Court set aside the order of dismissal and remanded the case for trial. On the first issue, the Court held that the union has the personality to file the suit as a representative party under Rule 3, Section 3 of the Rules of Court. The complaint was not a personal suit by the union but a representative suit expressly filed for the benefit of its fifty-seven named members. The Court distinguished but did not discard its ruling in National Brewery & Allied Industries Labor Union vs. San Miguel Brewery, Inc., which allowed a union to sue on a collective bargaining agreement. The principle extends to a union enforcing statutory rights for its members, as the union serves as the vehicle for collective action to enforce the workers’ individual claims. The union, as the recognized bargaining agent, possesses a sufficient interest in the welfare of its members to institute the action.
On the jurisdictional issue, the Court ruled that jurisdiction is determined by the aggregate amount of the claims in a single suit, not by the individual amounts. Since the complaint demanded a total of P22,189.25, which exceeds the P10,000.00 threshold for the Court of First Instance’s exclusive original jurisdiction, that court correctly possessed jurisdiction. The alternative of requiring fifty-seven separate suits for amounts under P10,000.00 was correctly rejected as absurd and contrary to the policy of avoiding multiplicity of suits. The aggregate claim doctrine applies, and the payment of a single filing fee based on the total demand is proper.