Feati University vs. Bautista

An educational institution operated for profit and declaring dividends to stockholders falls within the coverage of Republic Act No. 875 as an "employer," and its professors and instructors are "employees"—not independent contractors—entitled to self-organization and collective bargaining under the law. The term "employer" in Section 2(c) of Republic Act No. 875, which uses the word "includes," was deliberately drafted to be complementary and broad, encompassing all employers except those specifically excluded by the Act; educational institutions operated for profit are not among the exemptions.

Feati University is a private educational institution represented by its President, Mrs. Victoria L. Araneta. The Feati University Faculty Club-PAFLU is a duly registered labor union composed of professors and instructors of the University, affiliated with the Philippine Association of Free Labor Unions (PAFLU). The dispute arose under the framework of Republic Act No. 875 (the Industrial Peace Act or "Magna Carta of Labor"), which governed labor relations, and Commonwealth Act No. 103, which established the Court of Industrial Relations and defined its broad powers in cases involving strikes and lockouts. Section 10 of Republic Act No. 875 authorized the President of the Philippines to certify labor disputes in industries indispensable to the national interest to the CIR, thereby vesting that court with jurisdiction to act on the dispute.

On January 14, 1963, the President of the Feati University Faculty Club-PAFLU—hereinafter the Faculty Club—wrote to Mrs. Victoria L. Araneta, President of Feati University—hereinafter the University—informing her that the Faculty Club, composed of professors and instructors of the University, had been organized into a registered labor union. Eight days later, on January 22, 1963, the Faculty Club submitted a letter containing twenty-six demands related to the employment of its members, requesting a response within ten days. The University's President replied asking for at least thirty days to study the demands, while the University's counsel separately wrote to the Faculty Club demanding proof of its majority status and designation as a bargaining representative. On February 1, 1963, the Faculty Club rejected the request for an extension and, on the same day, filed a notice of strike with the Bureau of Labor, alleging the University's refusal to bargain collectively. Conciliation efforts at the Bureau of Labor failed, and on February 18, 1963, the Faculty Club members declared a strike and established picket lines on the University premises, disrupting classes. Further efforts by Department of Labor officials to settle the dispute proved fruitless.

On March 21, 1963, the President of the Philippines certified the dispute to the Court of Industrial Relations pursuant to Section 10 of Republic Act No. 875, citing that the University had approximately 18,000 students and 500 faculty members, that continued disruption would prejudice thousands of students, and that the dispute affected the national interest. The certification triggered three proceedings before the CIR. In CIR Case No. 41-IPA, relating to the strike, respondent Judge Jose S. Bautista set the case for hearing on March 23, 1963, where the parties agreed that striking faculty members would return to work and the University would readmit them under a status quo arrangement. That same day, however, the University filed a motion to dismiss, contending that the CIR lacked jurisdiction because the Industrial Peace Act did not apply to an educational institution or to faculty members who were independent contractors, and that the presidential certification was violative of Section 10 of the Act. On March 30, 1963, Judge Bautista denied the motion, declared the Industrial Peace Act applicable to both parties, and ordered the strikers to return to work and the University to readmit them under the last terms and conditions existing before the dispute, enjoining the University from dismissing any employee without prior CIR authorization. The University had, before that order, employed replacement professors and instructors. On April 6, 1963, Judge Bautista issued an implementing order warning the replacements not to disrupt the effectivity of the March 30 order.

Meanwhile, on March 8, 1963, the Faculty Club filed in CIR Case No. 1183-MC a petition for certification election, seeking to be certified as the sole and exclusive bargaining representative of all University employees. The University opposed the petition and moved to dismiss it on the same jurisdictional grounds raised in Case No. 41-IPA. Before Judge Baltazar Villanueva could act on the motion to dismiss, the Faculty Club moved to withdraw the petition on the ground that the issues had been absorbed by Case No. 41-IPA, which had been certified by the President. Judge Villanueva granted the withdrawal by order of April 6, 1963. Separately, in CIR Case No. V-30, the Acting Chief Prosecutor of the CIR filed a complaint for indirect contempt against President Araneta, Dean Daniel Salcedo, Executive Vice-President Rodolfo Maslog, and Assistant to the President Jose Segovia, charging them with violation of the March 30 return-to-work order. On April 29, 1963, Judge Bautista issued an order commanding any officer of the law to arrest the named officials, fixing bond at P500.00 each.

The University filed its petition for certiorari and prohibition with preliminary injunction before the Supreme Court on May 10, 1963, docketed as G.R. No. L-21278, seeking to annul the proceedings and questioned orders in all three CIR cases. The Supreme Court issued a writ of preliminary injunction the same day, enjoining Judge Bautista from further proceeding in those cases. While the motions for reconsideration of the CIR orders were still pending before the CIR en banc, the CIR en banc subsequently denied the University's motions for reconsideration: on June 5, 1963, for Case No. 1183-MC, and on May 7, 1963 (filed with the Clerk on June 28, 1963; received by the University on July 2, 1963), for Case No. 41-IPA. The University filed separate petitions for certiorari by way of appeal from those resolutions, docketed as G.R. No. L-21462 and G.R. No. L-21500, respectively. The Supreme Court ordered the three cases considered together on September 26, 1963. The University admitted that it declared dividends, and the CIR found in its March 30, 1963 order that the University realized profits and distributed part of its earnings as dividends to private stockholders.

• Inapplicability of RA 875 to Educational Institutions: The University argued that the Industrial Peace Act is not applicable to it because it is an educational institution and not an industrial establishment, and therefore not an "employer" within the contemplation of the Act. It cited several prior decisions excluding non-profit educational and charitable institutions from the Act's coverage.
• Faculty as Independent Contractors: The University maintained that the members of the Faculty Club are not employees but independent contractors, because the University does not exercise control over their work and merely leases their services pursuant to contracts for teaching services. It relied on Francisco's Labor Laws for the proposition that teachers are not included among "workers" performing physical labor.
• Invalidity of Presidential Certification: The University contended that the presidential certification was not authorized by, and was violative of, Section 10 of Republic Act No. 875, because the University is not an industrial establishment and there was no labor dispute in an industry indispensable to the national interest.
• Illegality of Return-to-Work Order: The University argued that Republic Act No. 875 had withdrawn the CIR's power to issue return-to-work orders; that Section 10 only authorized the CIR to prevent strikes or lockouts before they occurred, not after; that the taking in of replacement professors was valid and the return-to-work order impaired the obligation of contracts with replacements; and that the CIR could not issue the order without first determining the legality or illegality of the strike.
• Expiration of Teaching Contracts: The University maintained that because the individual teaching contracts of the striking faculty members had expired on March 25 or 31, 1963, there were no positions to which they could return, rendering the return-to-work order baseless.
• Illegality of Contempt Arrest Order: The University argued that the information for indirect contempt and the order of arrest were improper and illegal because its officers had complied in good faith with the return-to-work order, the order itself was illegal, and even if legal, it was not yet final due to a pending motion for reconsideration.
• Premature Filing of Certiorari: The Faculty Club alleged as a special defense that the petition for certiorari in G.R. No. L-21278 was prematurely filed because the questioned CIR orders were still subject to pending motions for reconsideration before the CIR en banc.
• Improper Withdrawal of Certification Election Petition: The University argued in G.R. No. L-21462 that the issues of employer-employee relationship, the Faculty Club's status as a labor union, and its majority representation should have been resolved first in Case No. 1183-MC before the issues in Case No. 41-IPA, and that the motion to withdraw the certification election petition should not have been granted.
• Violation of Injunction: The University alleged in G.R. Nos. L-21462 and L-21500 that the CIR en banc resolutions denying its motions for reconsideration were null and void because they were issued in violation of the writ of preliminary injunction issued in G.R. No. L-21278.

• CIR Jurisdiction via Presidential Certification: The Faculty Club argued that the CIR had acquired jurisdiction over Case No. 41-IPA by virtue of the presidential certification, and therefore had jurisdiction to issue the questioned orders in that case.
• Applicability of RA 875: The Faculty Club contended that the Industrial Peace Act is applicable to the University as an employer and to the Faculty Club members as employees affiliated with a duly registered labor union, giving the CIR jurisdiction over Cases Nos. 1183-MC and V-30.
• Premature Petition: The Faculty Club alleged that the petition for certiorari and prohibition in G.R. No. L-21278 was prematurely filed because the questioned CIR orders were still the subjects of pending motions for reconsideration before the CIR en banc.
• Injunction Not Violated: The Faculty Club argued that the CIR en banc resolution of June 5, 1963 did not violate the writ of preliminary injunction in G.R. No. L-21278 because the writ was issued against Judge Bautista personally and not against the Court of Industrial Relations as a body, much less against Judge Villanueva who was the trial judge in Case No. 1183-MC.
• Propriety of Withdrawal: The Faculty Club maintained that the lower court's order granting the withdrawal of the certification election petition was in accordance with law, the issues having been absorbed by the certified case.

• Applicability of RA 875 to Educational Institutions: Whether Republic Act No. 875 applies to Feati University, a for-profit educational institution, such that the CIR has jurisdiction over the parties and the subject matter of the dispute.
• Status of Faculty Members as Employees: Whether the professors and instructors of the University are employees within the meaning of Republic Act No. 875, or independent contractors, and consequently whether they have the right to unionize.
• Validity of Presidential Certification: Whether the presidential certification of the labor dispute to the CIR under Section 10 of Republic Act No. 875 was valid.
• Validity of Return-to-Work Order: Whether the CIR had the power and jurisdiction to issue the return-to-work order of March 30, 1963 and the implementing order of April 6, 1963.
• Validity of Contempt Arrest Order: Whether the CIR had jurisdiction to issue the order of April 29, 1963 for the arrest of university officials in the indirect contempt proceedings.
• Propriety of Withdrawal of Certification Election Petition: Whether the CIR properly granted the withdrawal of the petition for certification election in Case No. 1183-MC.

• Applicability of RA 875 to Educational Institutions: Yes. Republic Act No. 875 applies to Feati University because it is operated for profit and declares dividends to stockholders, placing it within the scope of the Act as an "employer."
• Status of Faculty Members as Employees: Yes. The professors and instructors are employees, not independent contractors, because the University controls the manner and conditions of their work, and they are entitled to self-organization under Section 3 of Republic Act No. 875.
• Validity of Presidential Certification: Yes. The certification was valid, the existence of a labor dispute involving terms and conditions of employment and representation having been established, and the propriety of the President's exercise of his certification power being beyond judicial review.
• Validity of Return-to-Work Order: Yes. The CIR had the authority to issue the return-to-work order as part of its broad powers under Commonwealth Act No. 103, as supplemented by Section 10 of Republic Act No. 875, which empowers it to fix terms and conditions of employment in certified cases.
• Validity of Contempt Arrest Order: Yes. The CIR had jurisdiction to issue the arrest order in the indirect contempt proceedings, the return-to-work order allegedly violated being within the court's jurisdiction to issue and immediately executory under Section 14 of Commonwealth Act No. 103.
• Propriety of Withdrawal of Certification Election Petition: Yes. The CIR did not err in granting the withdrawal, as all questions relating to the labor dispute could be threshed out and decided in the main certified case, No. 41-IPA.

• Applicability of RA 875 to Educational Institutions: The Court reviewed prior decisions excluding non-profit educational and charitable institutions from the coverage of Republic Act No. 875—Boy Scouts of the Philippines vs. Araos, University of San Agustin vs. CIR, University of Santo Tomas vs. Villanueva, and La Consolacion College vs. CIR—and found that the controlling distinction was whether the institution was operated for profit. In all those cases, the institutions were not organized for profit and did not declare dividends. By contrast, in Far Eastern University vs. CIR, the Court unanimously upheld the application of the Act to an educational institution that made profits. The University itself admitted that it declared dividends, and the CIR found that it realized profits distributed as dividends to private stockholders. The Court accordingly held it a settled doctrine that the Industrial Peace Act applies to any organization or entity—whatever its purpose when created—that is operated for profit or gain. The Court further held that the term "employer" in Section 2(c), which uses the word "includes" rather than "means," was deliberately drafted to be complementary and broad, encompassing all employers except those specifically excluded by the Act. Educational institutions are not among the statutory exemptions. The term "industry" was likewise given a broad meaning to cover all enterprises operated for profit that engage the services of persons who work to earn a living.

• Status of Faculty Members as Employees: The Court rejected the University's claim that its faculty members were independent contractors. Section 2(d) of Republic Act No. 875 defines "employee" using the word "include," making the definition complementary rather than restrictive. The University admitted that the professors and instructors were under contract to teach particular courses and were paid for their services, satisfying the ordinary meaning of "employee." The Court took judicial notice that a university controls the work of its faculty—prescribing courses, scheduling, and locations; that the work is characterized by regularity and continuity for fixed durations; that professors are compensated by wages rather than profits; that they cannot substitute others without the university's consent; and that they can be laid off for unsatisfactory work. The right-to-control test, not the actual exercise of control, is the principal consideration in distinguishing employees from independent contractors. The Court further noted that even if professors were considered independent contractors, they would still be covered by Republic Act No. 875, because the Act—modeled after the Wagner Act—did not exclude independent contractors from the definition of "employee." The Court held that faculty members of private educational institutions, whether run for profit or not, are "employees" entitled to the protection of labor laws, including the right to self-organization under Section 3 of the Act, a right guaranteed by the Constitution.

• Validity of Presidential Certification: The Court found that a labor dispute existed between the University and the Faculty Club, as defined in Republic Act No. 875, because the controversy involved terms and conditions of employment and the question of representation. The admitted facts—the Faculty Club's demands, the University's refusal to bargain, the notice of strike, the strike itself, and the filing of unfair labor practice and certification election cases—all demonstrated a labor dispute. Having established that the University is an employer operated for profit and that an employer-employee relationship and a labor dispute existed, the Court held the presidential certification valid. Citing Pampanga Sugar Development Co. vs. CIR, the Court ruled that the propriety of the President's exercise of his certification power is a matter that devolves upon him alone, and neither the CIR nor the Supreme Court may pass upon the correctness of the President's reasons. Once the certification is made, the CIR acquires exclusive jurisdiction and may exercise its broad powers under Commonwealth Act No. 103.

• Validity of Return-to-Work Order: The Court held that Republic Act No. 875 did not withdraw the CIR's power to issue return-to-work orders. When a case is certified by the President, it comes under the operation of Commonwealth Act No. 103, and the CIR exercises the broad powers granted by that Act. Section 10 of Republic Act No. 875 empowers the CIR to issue an order "fixing the terms of employment," which is broad enough to authorize ordering strikers to return to work and the employer to readmit them. Citing Philippine Marine Officers Association vs. CIR and Hind Sugar Co. vs. CIR, the Court held that the CIR's power of conciliation and arbitration includes the power to carry its solution into effect. The Court also rejected the argument that the CIR could only act before a strike occurred, citing Bisaya Land Transportation Co. vs. CIR for the proposition that presidential certification is not limited to the prevention of strikes. The return-to-work order was also a confirmation of an agreement reached during the prehearing conference on March 23, 1963. The employment of replacements was a temporary expedient not authorized by the CIR and did not vest permanent rights in the replacements. The order did not impair the obligation of contracts, because labor contracts must yield to the common good under Article 1700 of the Civil Code. The Court distinguished Philippine Can Company vs. CIR, where the legality of the strike had to be determined first, because that case did not involve the national interest, was not certified by the President, and involved a company facing bankruptcy that no longer needed the strikers' services—circumstances absent here. The expiration of individual teaching contracts did not defeat the return-to-work order, because Section 2(d) of Republic Act No. 875 includes among employees any individual whose work has ceased as a consequence of a current labor dispute, fixing the strikers' status as employees for purposes of the controversy.

• Validity of Contempt Arrest Order: The Court held that the CIR had jurisdiction to issue the arrest order. Section 6 of Commonwealth Act No. 103 empowers the CIR to punish direct and indirect contempts under Rule 71 of the Rules of Court. Section 3 of Rule 71 enumerates disobedience of lawful court orders as indirect contempt and authorizes the court to issue process to bring the accused into court or hold him in custody pending proceedings. The return-to-work order allegedly violated was within the CIR's jurisdiction to issue. Under Section 14 of Commonwealth Act No. 103, orders in cases involving strikes and lockouts are immediately executory, and appeal does not stay execution unless the Supreme Court specially orders otherwise. Therefore, even non-final orders may be the subject of contempt proceedings. Section 19 of Commonwealth Act No. 103 further provides that violation of the implied condition in every contract of employment—including the duty to return to work upon court order—constitutes contempt of the CIR. The arrest order was not a punishment but merely a means to bring the accused officials before the court to be dealt with according to law; their guilt had yet to be determined in a proper hearing.

• Propriety of Withdrawal of Certification Election Petition: The Court held that the CIR did not err in granting the withdrawal. All questions relating to the labor dispute between the University and the Faculty Club could be threshed out and decided in the main certified case, No. 41-IPA. The University had sought the dismissal of the certification election petition, and the withdrawal had in a way produced the situation desired by the University. The Court found no error in the CIR's ruling that the issues in Case No. 1183-MC were absorbed by Case No. 41-IPA.

• Applicability of the Industrial Peace Act to Profit-Seeking Educational Institutions — The Industrial Peace Act (Republic Act No. 875) applies to any organization or entity—whatever its purpose when created—that is operated for profit or gain. Educational institutions that are organized, operated, and maintained for profit and declare dividends to stockholders fall within the scope of the Act and are "employers" thereunder. Non-profit educational institutions, by contrast, are beyond the purview of the Act. The Court applied this doctrine by finding that Feati University admitted it declared dividends and the CIR found it realized profits distributed to private stockholders, thereby bringing it within the coverage of the Act.

• Statutory Construction: "Includes" vs. "Means" — The use of the word "includes" in defining "employer" [Section 2(c)] and "employee" [Section 2(d)] of Republic Act No. 875, as opposed to the word "means" used in defining other terms, was deliberate and purposeful, indicating that the definitions are complementary rather than exhaustive. Congress intended the terms "employer" and "employee" to be understood in their broad, ordinary meaning, with only those entities specifically excluded by the Act falling outside their scope. The Court relied on this distinction to reject the University's argument that only "industrial establishments" could be employers under the Act.

• Right to Control as Test of Employment — The principal consideration in determining whether a worker is an employee or an independent contractor is the right to control the manner of doing the work—not the actual exercise of that right, but the existence of the right to control. Indicia of employment include: regularity and continuity of work for a fixed duration; compensation by wages rather than profits; inability to substitute another without the employer's consent; and the power of the employer to lay off the worker for unsatisfactory work. The Court applied this test by taking judicial notice that a university controls its faculty's work—prescribing courses, schedules, and locations—and that professors cannot substitute others without consent.

• Striking Employees Retain Employee Status — Striking employees do not abandon their employment by declaring a strike; they only cease from their labor. Their status as employees is fixed for purposes of the labor controversy, and they remain employees even after the expiration of their individual contracts, pursuant to Section 2(d) of Republic Act No. 875, which includes among employees "any individual whose work has ceased as a consequence of, or in connection with, any current labor dispute." The Court applied this doctrine to reject the University's argument that the expiration of teaching contracts defeated the return-to-work order.

• Presidential Certification as Executive Prerogative — Under Section 10 of Republic Act No. 875, the propriety of the President's exercise of his power to certify a labor dispute to the CIR is a matter that devolves upon the President alone. Neither the CIR nor the Supreme Court may pass upon the correctness of the President's reasons for certifying the dispute. Once certified, the CIR acquires exclusive jurisdiction and may exercise its broad powers under Commonwealth Act No. 103. The Court applied this doctrine by refusing to question the President's certification, which cited the University's 18,000 students, 500 faculty members, and the effect on the national interest.

• CIR's Power to Issue Return-to-Work Orders in Certified Cases — When a labor dispute is certified by the President to the CIR under Section 10 of Republic Act No. 875, the CIR may issue return-to-work orders as part of its broad powers under Commonwealth Act No. 103, including the power to "fix the terms and conditions of employment." This power is not limited to preventing strikes before they occur but extends to situations where a strike has already been declared. The Court applied this doctrine by upholding the March 30, 1963 return-to-work order, which was also a confirmation of an agreement reached during a prehearing conference.

• Immediate Executory Nature of CIR Orders in Strike/Lockout Cases — Under Section 14 of Commonwealth Act No. 103, orders, awards, and decisions of the CIR in cases involving strikes and lockouts are immediately executory, and appeal does not stay execution unless the Supreme Court specially orders otherwise. Disobedience of such orders, even if not yet final, may constitute indirect contempt. The Court applied this doctrine to uphold the contempt arrest order against university officials.

• "We consider it a settled doctrine of this Court, therefore, that the Industrial Peace Act is applicable to any organization or entity — whatever may be its purpose when it was created — that is operated for profit or gain." — This passage articulates the controlling rule that determines whether an educational institution falls within the coverage of Republic Act No. 875, distinguishing profit-seeking institutions from non-profit ones.

• "In using the word 'includes' and not 'means', Congress did not intend to give a complete definition of 'employer', but rather that such definition should be complementary to what is commonly understood as employer." — This passage establishes the statutory construction principle underlying the broad interpretation of "employer" and "employee" under Republic Act No. 875, distinguishing the complementary "includes" from the exhaustive "means."

• "Certainly, professors, instructors or teachers of private educational institutions who teach to earn a living are entitled to the protection of our labor laws — and one such law is Republic Act No. 875." — This passage declares the right of faculty members of private educational institutions to the protection of labor laws, including the right to self-organization, regardless of whether the institution is run for profit or not.

• "To certify a labor dispute to the CIR is the prerogative of the President under the law, and this Court will not interfere in, much less curtail, the exercise of that prerogative." — This passage defines the scope of judicial review of presidential certifications under Section 10 of Republic Act No. 875, establishing that the propriety of the certification is beyond judicial inquiry.

• Boy Scouts of the Philippines vs. Araos, G.R. No. L-10091, January 29, 1958 — Controlling precedent for the proposition that Republic Act No. 875 does not apply to entities organized not for profit but for charitable, educational, or similar elevated purposes. Distinguished in the present case because Feati University is operated for profit and declares dividends.

• University of San Agustin vs. CIR, G.R. No. L-12222, May 28, 1958 — Followed for the ruling that a non-profit educational institution conducted by a religious non-stock corporation is beyond the purview of Republic Act No. 875. Distinguished because Feati University operates for profit.

• University of Santo Tomas vs. Hon. Baltazar Villanueva, et al., G.R. No. L-13748, October 30, 1959 — Followed for the ruling that an educational institution not organized for profit, which declares no dividends, is not an industrial or business organization and is outside the CIR's jurisdiction. Distinguished on the same profit basis.

• La Consolacion College vs. CIR, G.R. No. L-13282, April 22, 1960 — Followed for the same ruling that non-profit educational institutions are beyond the CIR's jurisdiction. Distinguished on the same profit basis.

• Far Eastern University vs. CIR, G.R. No. L-17620, August 31, 1962 — Controlling precedent for the proposition that an educational institution operated for profit comes within the scope of Republic Act No. 875. The Court was unanimous on this point. Applied directly to Feati University, which admitted declaring dividends.

• Pampanga Sugar Development Co. vs. CIR, G.R. No. L-13178, March 24, 1961 — Controlling precedent on presidential certification under Section 10 of Republic Act No. 875, holding that the CIR cannot throw out a certified case on the assumption that the certification was erroneous, and that the propriety of the certification is the President's concern alone. Applied directly.

• Philippine Marine Officers Association vs. CIR and Compañia Maritima vs. Philippine Marine Radio Officers Association, G.R. Nos. L-10095 and L-10115, October 31, 1957 — Followed for the ruling that upon presidential certification, the CIR exercises the broad powers of Commonwealth Act No. 103, including the power to order strikers to return to work.

• Bisaya Land Transportation Co. vs. CIR, G.R. No. L-10114, November 26, 1957 — Followed for the ruling that presidential certification is not limited to preventing strikes and lockouts but may be made even after a strike has been declared.

• Philippine Can Company vs. CIR, G.R. No. L-3021, July 13, 1950 — Distinguished. The Court declined to apply its ruling that the legality of a strike must be determined before issuing a return-to-work order, because that case did not involve the national interest, was not certified by the President, and involved a company facing bankruptcy that no longer needed the strikers' services.

• Rizal Cement Co., Inc. vs. Rizal Cement Workers Union (FFW), G.R. No. L-12747, July 30, 1960 — Cited for the proposition that the CIR's jurisdiction in a certified case is exclusive.

• Hind Sugar Co. vs. CIR, G.R. No. L-13364, July 26, 1960 — Followed for the ruling that the solution found by the CIR under the authority of a presidential certification cannot be questioned.

• The Angat River Irrigation System vs. Angat River Workers' Union (PLUM), G.R. Nos. L-10934 and L-10944, December 28, 1957 — Cited for the definition of "employer" as one who employs the services of others and pays their wages or salaries.

• Section 2(c), Republic Act No. 875 (Industrial Peace Act) — Defines "employer" using the word "includes," encompassing any person acting in the interest of an employer, directly or indirectly, but excluding labor organizations and their agents. The Court construed this as a complementary, not exhaustive, definition, bringing within its scope all employers except those specifically excluded by the Act.

• Section 2(d), Republic Act No. 875 — Defines "employee" using the word "include," not limited to employees of a particular employer, and including any individual whose work has ceased as a consequence of a current labor dispute. The Court applied this provision to hold that striking faculty members retained their status as employees despite the expiration of their teaching contracts.

• Section 3, Republic Act No. 875 — Guarantees employees' right to self-organization and to form, join, or assist labor organizations for collective bargaining and concerted activities. The Court held that faculty members of private educational institutions are entitled to this right.

• Section 10, Republic Act No. 875 — Authorizes the President to certify labor disputes in industries indispensable to the national interest to the CIR, which may then issue restraining orders or orders fixing terms and conditions of employment. The Court upheld the validity of the presidential certification and the CIR's consequent jurisdiction.

• Section 6, Commonwealth Act No. 103 — Empowers the CIR to punish direct and indirect contempts under the Rules of Court. The Court held that this provision, read with Section 14, authorized contempt proceedings for disobedience of CIR orders even before they became final.

• Section 14, Commonwealth Act No. 103 — Provides that in cases involving strikes and lockouts, appeal to the Supreme Court does not stay execution of the CIR's award, order, or decision unless the Supreme Court specially orders otherwise. The Court held that this makes CIR orders immediately executory, such that disobedience may constitute contempt even if the order is under reconsideration or appeal.

• Section 19, Commonwealth Act No. 103 — Provides an implied condition in every contract of employment that employees shall return to work upon court order when public interest requires, and that violation of such order constitutes contempt of the CIR. The Court applied this provision to sustain the contempt proceedings against university officials.

• Article 1700, Civil Code — Provides that labor contracts must yield to the common good and are subject to special laws on labor unions, collective bargaining, strikes, and similar subjects. The Court invoked this provision to reject the impairment-of-contracts argument raised by the University regarding its contracts with replacement professors.

• Section 3, Rule 71, Rules of Court — Enumerates acts constituting indirect contempt, including disobedience of lawful court orders, and authorizes the court to issue process to bring the accused into court or hold him in custody pending proceedings. The Court held that this provision authorized the arrest order issued by Judge Bautista.

Concepcion, C.J., Dizon, Regala, Makalintal, Bengzon, J.P., Sanchez, and Castro, JJ., concurred. Reyes, J.B.L., J., concurred but reserved his vote on the teacher's right to strike.