1) The Agricultural Credit Administration (ACA) was created through a reorganization of the Agricultural Credit and Cooperative Financing Administration (ACCFA) to implement the Philippine government's land reform program.
2) Labor unions representing ACCFA employees previously had a collective bargaining agreement with ACCFA but claimed ACA refused to recognize this. They filed a complaint.
3) ACA argued it was a government entity carrying out sovereign functions, not a proprietary agency, so it did not have an obligation to bargain with unions. However, the courts ruled in favor of the unions.
4) On appeal, the Supreme Court determined that implementing land reform was purely a governmental function beyond the capabilities of private enterprise. As
1) The Agricultural Credit Administration (ACA) was created through a reorganization of the Agricultural Credit and Cooperative Financing Administration (ACCFA) to implement the Philippine government's land reform program.
2) Labor unions representing ACCFA employees previously had a collective bargaining agreement with ACCFA but claimed ACA refused to recognize this. They filed a complaint.
3) ACA argued it was a government entity carrying out sovereign functions, not a proprietary agency, so it did not have an obligation to bargain with unions. However, the courts ruled in favor of the unions.
4) On appeal, the Supreme Court determined that implementing land reform was purely a governmental function beyond the capabilities of private enterprise. As
1) The Agricultural Credit Administration (ACA) was created through a reorganization of the Agricultural Credit and Cooperative Financing Administration (ACCFA) to implement the Philippine government's land reform program.
2) Labor unions representing ACCFA employees previously had a collective bargaining agreement with ACCFA but claimed ACA refused to recognize this. They filed a complaint.
3) ACA argued it was a government entity carrying out sovereign functions, not a proprietary agency, so it did not have an obligation to bargain with unions. However, the courts ruled in favor of the unions.
4) On appeal, the Supreme Court determined that implementing land reform was purely a governmental function beyond the capabilities of private enterprise. As
1) The Agricultural Credit Administration (ACA) was created through a reorganization of the Agricultural Credit and Cooperative Financing Administration (ACCFA) to implement the Philippine government's land reform program.
2) Labor unions representing ACCFA employees previously had a collective bargaining agreement with ACCFA but claimed ACA refused to recognize this. They filed a complaint.
3) ACA argued it was a government entity carrying out sovereign functions, not a proprietary agency, so it did not have an obligation to bargain with unions. However, the courts ruled in favor of the unions.
4) On appeal, the Supreme Court determined that implementing land reform was purely a governmental function beyond the capabilities of private enterprise. As
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ACCFA v CUGCO Digest as to the governmental character of its functions
disappears.
G.R. No. L-21484 November 29, 1969
The growing complexities of modern society, however, Facts: have rendered this traditional classification of the 1. ACCFA, a government agency created under functions of government quite unrealistic, not to say RA 821, as amended was reorganized and its name obsolete. The areas which used to be left to private changed to Agricultural Credit Administration (ACA) enterprise and initiative and which the government was under the RA 3844 or Land Reform Code. While called upon to enter optionally, and only "because it ACCFA Supervisors' Association (ASA) and the was better equipped to administer for the public ACCFA Workers' Association (AWA), are labor welfare than is any private individual or group of organizations (the Unions) composed of the individuals,"5continue to lose their well-defined supervisors and the rank-and-file employees in the boundaries and to be absorbed within activities that ACCFA. the government must undertake in its sovereign capacity if it is to meet the increasing social challenges 2. A CBA was agreed upon by labor unions (ASA of the times. Here as almost everywhere else the and AWA) and ACCFA. The said CBA was supposed tendency is undoubtedly towards a greater to be effective on 1 July 1962. Due to non- socialization of economic forces. Here of course this implementation of the CBA the unions held a strike. development was envisioned, indeed adopted as a And 5 days later, the Unions, with its mother union, the national policy, by the Constitution itself in its Confederation of Unions in Government Corporations declaration of principle concerning the promotion of and Offices (CUGCO), filed a complaint against social justice. ACCFA before the CIR on ground of alleged acts of unfair labor practices; violation of the collective bargaining agreement in order to discourage the The Unions have no bargaining rights with ACA. EO members of the Unions in the exercise of their right to 75 placed ACA under the LRPA and by virtue of RA self-organization, discrimination against said members 3844 the implementation of the Land Reform Program in the matter of promotions and refusal to bargain. of the government is a governmental function NOT a 3. ACCFA moved for a reconsideration but while proprietary function. Being such, ACA can no longer the appeal was pending, RA 3844 was passed which step down to deal privately with said unions as it may effectively turned ACCFA to ACA. Then, ASA and have been doing when it was still ACCFA. However, AWA petitioned that they obtain sole bargaining rights the growing complexities of modern society have with ACA. While this petition was not yet decided rendered the classification of the governmental upon, EO 75 was also passed which placed ACA functions as unrealistic, if not obsolete. Ministerial and under the Land Reform Project Administration. governmental functions continue to lose their well- Notwithstanding the latest legislation passed, the trial defined boundaries and are absorbed within the court and the appellate court ruled in favor of ASA and activities that the government must undertake in its AWA. sovereign capacity if it to meet the increasing social challenges of the times and move towards a greater ISSUE: W/N ACA is a government entity socialization of economic forces.
YES.
It was in furtherance of such policy that the Land
Reform Code was enacted and the various agencies, the ACA among them, established to carry out its purposes. There can be no dispute as to the fact that the land reform program contemplated in the said Code is beyond the capabilities of any private enterprise to translate into reality. It is a purely governmental function, no less than, the establishment and maintenance of public schools and public hospitals. And when, aside from the governmental objectives of the ACA, geared as they are to the implementation of the land reform program of the State, 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