RILECO, INC., PETITIONER, VS. MINDANAO CONGRESS OF LABOR-RAMIE UNITED FARM WORKER’S ASSOCIATION (LOCAL) AND THE COURT OF INDUSTRIAL RELATIONS, RESPONDENTS.

Rileco versus Mindanao Congress of Labor-Ramie United Farm Workers Association

The Case

This is a petition for certiorari brought by Rileco, Incorporated against the Mindanao Congress of Labor-Ramie United Farm Workers Association, Local, and the Court of Industrial Relations. Rileco owns the Manolita Plantation, where it is engaged in ramie culture. The union filed a petition for a certification election among the plantation workers, and the Court of Industrial Relations ordered that election held. Rileco asks the Supreme Court to set that order aside on a single ground: that the plantation is agricultural, and therefore the Court of Industrial Relations had no jurisdiction over the labor dispute. The case matters because it draws the line between agricultural and industrial undertakings under the law that defines those terms, and because it tells us that the use of machines does not by itself convert farming into industry.

Procedural History

The Mindanao Congress of Labor-Ramie United Farm Workers Association, Local, a legitimate labor organization, filed a petition for certification election before the Court of Industrial Relations. It alleged that more than ten percent of the employees and laborers of the Manolita Plantation were its members, and that no certification election had been held there in the twelve months before the filing. Rileco moved to dismiss, arguing that a valid and binding collective bargaining agreement already existed between it and the Ledesma Plantation Laborers Union, a duly registered union representing a majority of the employees. Rileco then filed a supplemental motion to dismiss, arguing that the Court of Industrial Relations had no jurisdiction because the Manolita Plantation was engaged solely in agricultural work and its laborers were agricultural laborers. On April 22, 1963, the Court of Industrial Relations issued the order appealed from, requesting the Department of Labor to conduct an election among the eligible workers in the ramie culture of the Manolita Plantation, in a unit composed of one hundred seventy-six workers, with the contending unions named. Rileco then came to the Supreme Court by writ of certiorari.

Facts

Rileco operates the Manolita Plantation, where it is admittedly engaged in ramie culture. The union sought a certification election among the workers of that plantation. Rileco resisted, first on the ground of an existing collective bargaining agreement with another union, and then on the ground that the plantation's work is agricultural and outside the jurisdiction of the Court of Industrial Relations.

The Court of Industrial Relations described the whole process of ramie culture at the plantation. The soil is prepared, ramie roots are planted and cared for at least one hundred days, and the stalks are then cut and delivered to stripping sheds. There the stalks are stripped with decorticating machines powered by electricity. The wet fibers are dried under the sun for one day and then passed through a brusher to cleanse them of impurities. After that, the fibers are ready for the market.

The Court of Industrial Relations nevertheless ordered a certification election. Rileco appealed to the Supreme Court, raising the single question of whether ramie culture is agricultural or industrial.

Issues

• Whether or not the ramie culture in which Rileco is engaged at its Manolita Plantation is an agricultural undertaking, such that the Court of Industrial Relations had no jurisdiction over the certification election.

Applicable Provisions

Section 2 of Republic Act Number 602 defines agricultural work, and it is the provision on which the entire case turns:

"'Agricultural' includes farming in all its branches and among other things includes the cultivation and tillage of the soil, dairying, the production, cultivation, growing, and harvesting of any agricultural or horticultural commodities, the raising of livestock or poultry, and any practices performed by a farmer or on farm as an incident to or in conjunction with some farming operations, but does not include the manufacturing or processing of sugar, coconuts, abaca, tobacco, pineapples or other farm products."

The definition controls because if ramie culture falls within it, the work is agricultural and the Court of Industrial Relations had no jurisdiction to order the election.

Ruling

The Court ruled that the ramie process or culture described in the appealed order is purely agricultural in character. It reached this conclusion by comparing the process to the one it had already examined in the Celestial case, which involved an experimental station that tilled the soil, planted and cultivated the best crop varieties, harvested them, and extracted the seeds for sale. The Court held in that case:

"Where an experimental station operates a farm comprising 960 hectares, and, through its employees and laborers actually tills the soil, introduces and plants seeds of the best crop (principally cacao) varieties found by it after study and experiment, raises said crops in the best approved methods of cultivation, including the spacing of each plant or seedling and the amount of water needed through irrigation, weeding, etc. and the proper harvesting of the crops, including the timing and method, discovers plant pests and their eradication by means of treatment with the proper insecticides, and, thereafter, extracts the seeds from the harvest for sale and distribution to farmers, there can be no question that all these acts and functions ... are agricultural as distinguished from non-agricultural functions."

Although the Celestial case involved cacao and other plant seeds, the Court found a great similarity between those processes and the ones involved in ramie culture. The Court also noted that the Court of Industrial Relations itself, in an earlier certification case involving the Odel Plantation, had held that the production of hemp, abaca and copra, and the use of stripping machines in connection with harvesting, ending with the classification and packaging of the products ready for marketing, are purely agricultural work. In that ruling, the processing did not convert the abaca into another product, and the mere use of modern machines as a labor saving device did not alter the agricultural nature of the product. The Court said this was not binding on it, but was a reasonable construction of the law and must be applied likewise to the processing of ramie fiber. Because the work is agricultural, the Court of Industrial Relations had no jurisdiction, and the order had to be set aside.

Doctrine

Ramie culture is agricultural work within the meaning of Section 2 of Republic Act Number 602. The definition of agricultural work includes farming in all its branches, the cultivation and tillage of the soil, and the production, cultivation, growing and harvesting of agricultural commodities, together with practices performed by a farmer or on a farm as an incident to or in conjunction with farming operations. The definition excludes only the manufacturing or processing of sugar, coconuts, abaca, tobacco, pineapples or other farm products. Where the process ends with the fiber ready for market and does not convert the raw product into another product, the work remains agricultural. The use of modern machines, such as decorticating machines and brushers, as a labor saving device does not change the agricultural character of the undertaking. Because the work is agricultural, the Court of Industrial Relations has no jurisdiction over a certification election among the plantation's laborers.

Disposition

The Supreme Court granted the writ, set aside the order of the Court of Industrial Relations, and ruled that the ramie culture is purely agricultural, with costs against the respondents.

Remember This

The line to memorize is this: processing that does not convert the farm product into another product, even with the use of machines, remains agricultural. Examiners use this case to test the agricultural versus industrial distinction under Republic Act Number 602 and the jurisdictional consequence that follows from it.