Republic Act No. 3350, which amends Section 4(a)(4) of the Industrial Peace Act (R.A. No. 875) by exempting members of religious sects prohibiting affiliation with labor organizations from the coverage of closed shop agreements, is constitutional. It validly protects the fundamental right to freedom of religion without unduly infringing upon other constitutional rights or established legal principles.

The case arose from a conflict between an employee's religious beliefs prohibiting labor union membership and a collective bargaining agreement's closed shop provision. Benjamin Victoriano, an employee of Elizalde Rope Factory Inc. and a member of the Iglesia ni Cristo, a religious sect prohibiting its members from joining labor organizations, was compelled by a closed shop agreement between his employer and the Elizalde Rope Workers' Union to be a member of the Union. Following the enactment of R.A. No. 3350, which exempts such individuals from closed shop provisions, Victoriano resigned from the Union. The Union then demanded his dismissal from the company, leading to the legal challenge.

• Benjamin Victoriano, an employee of Elizalde Rope Factory Inc. since 1958, was a member of the religious sect "Iglesia ni Cristo" and also a member of the Elizalde Rope Workers' Union.
• The Union had a collective bargaining agreement (CBA) with the Company containing a closed shop provision requiring membership in the Union as a condition of employment for all permanent employees.
• The CBA expired on March 3, 1964, and was renewed the following day, March 4, 1964.
• On June 18, 1961, Republic Act No. 3350 was enacted, amending Section 4(a), paragraph 4 of R.A. No. 875 (Industrial Peace Act), stating that closed shop agreements "shall not cover members of any religious sects which prohibit affiliation of their members in any such labor organization".
• Victoriano, whose religion prohibits affiliation with labor organizations, presented his resignation to the Union in 1962, and reiterated it on September 3, 1974 (likely a typo in the decision, should be an earlier date, possibly 1964, given the context of the CBA renewal and subsequent events).
• The Union requested the Company to dismiss Victoriano due to his resignation from the Union.
• The Company notified Victoriano that he would be dismissed unless he could make a satisfactory arrangement with the Union.
• Victoriano filed an action for injunction in the Court of First Instance (CFI) of Manila to prevent his dismissal.
• The CFI ruled in favor of Victoriano, enjoining his dismissal and ordering the Union to pay attorney's fees.
• The Union appealed to the Supreme Court, challenging the constitutionality of R.A. No. 3350.

• The Elizalde Rope Workers' Union (appellant) argued that Republic Act No. 3350 is unconstitutional because it infringes on the fundamental right to form lawful associations by effectively prohibiting members of certain religious sects from joining any labor union if their sect forbids it.
• The Union contended that R.A. No. 3350 impairs the obligation of contracts, specifically the "union security clause" in its CBA with the company, by relieving the employer of its obligation to cooperate in maintaining union membership and depriving the union of dues from exempted members.
• The Union asserted that R.A. No. 3350 discriminatorily favors religious sects that ban union membership, violating the equal protection clause and the constitutional provision against religious tests for the exercise of civil rights.
• The Union claimed that R.A. No. 3350 violates the constitutional provision regarding the promotion of social justice.
• The Union argued that a "closed shop provision" is not violative of religious freedom and that R.A. No. 3350, if upheld, would wipe out trade unionism as employers would prefer to hire members of Iglesia ni Cristo.
• The Union contended that the lower court erred in sentencing it to pay attorney's fees, arguing it contravenes Section 24 of R.A. No. 875 and Article 2208 of the Civil Code, as the action involved an industrial dispute and Victoriano was not actually dismissed.

• Benjamin Victoriano (appellee) argued that Republic Act No. 3350 does not violate the right to form lawful associations, as this right includes the right not to join or to resign from a labor organization if one's conscience dictates, and the Act gives substance to this right.
• Victoriano contended that R.A. No. 3350 does not impair the obligation of contracts because the law formed part of and was incorporated into the terms of the closed shop agreement.
• Victoriano asserted that the Act does not violate the establishment of religion clause or separation of Church and State, as Congress merely accommodated the religious needs of workers and balanced collective labor rights with individual religious freedom, giving primacy to the latter.
• Victoriano claimed that R.A. No. 3350 does not violate the equal protection clause, as the classification of workers based on religious tenets is based on substantial distinction, germane to the law's purpose, and applies to all members of the class.
• Victoriano argued that the Act does not violate the social justice policy of the Constitution, as it was enacted to equalize employment opportunities amidst diverse religious beliefs.
• Victoriano maintained that there was no industrial dispute involved in compelling him to maintain union membership under pain of dismissal and that the Union's act inflicted intentional harm, justifying the award of attorney's fees.

• Whether Republic Act No. 3350 is unconstitutional on the grounds that it infringes on the freedom of association, impairs the obligation of contracts, violates the establishment of religion and free exercise clause, requires a religious test for the exercise of a civil right, denies equal protection of the laws, or violates the promotion of social justice.
• Whether the lower court erred in ordering the appellant Union to pay attorney's fees to the appellee.

• The Supreme Court affirmed the decision of the Court of First Instance, holding that Republic Act No. 3350 is constitutional. The Court reasoned that R.A. No. 3350 does not prohibit members of religious sects from joining unions but merely exempts them from the compulsion of closed shop agreements if their religion forbids such affiliation, thus upholding freedom of association which includes the right not to join.
• The Court found that while R.A. No. 3350 does impair the union security clause of the CBA, such impairment is a legitimate exercise of police power, as the prohibition against impairing contracts is not absolute and must yield to the State's power to safeguard vital public interests, including freedom of religion and the right to work.
• The Court held that R.A. No. 3350 does not violate the "no-establishment" clause as its purpose is secular (protecting the right to work and free exercise of religion) and its primary effect neither advances nor inhibits religion. It merely accommodates religious beliefs.
• The Court determined that R.A. No. 3350 does not require a religious test; it exempts individuals ipso jure based on their religious affiliation without requiring any positive act to exercise a right.
• The Court ruled that R.A. No. 3350 does not violate the equal protection clause because the classification of employees based on religious beliefs prohibiting union membership rests on substantial distinctions, is germane to the law's purpose of protecting religious freedom and the right to work, is not limited to existing conditions, and applies equally to all members of the specified class.
• The Court concluded that R.A. No. 3350 promotes social justice by ensuring equal opportunity for work irrespective of religious scruples.
• Regarding the award of attorney's fees, the Court held that Section 24 of R.A. No. 875 was not applicable as the Union's act of demanding dismissal was the labor dispute itself, not an act in furtherance of one. The award was justified under Article 2208 of the Civil Code as the Union's action compelled Victoriano to incur expenses to protect his interest.

• Presumption of Constitutionality — All presumptions are indulged in favor of constitutionality; one who attacks a statute, alleging unconstitutionality, must prove its invalidity beyond a reasonable doubt. This doctrine was invoked as a foundational principle for analyzing the constitutionality of R.A. No. 3350, requiring the Union to overcome this presumption.
• Freedom of Association — The right to form associations or societies for purposes not contrary to law shall not be abridged; this includes the right to join a union and, correlatively, the right to abstain from joining any union. The Court held that R.A. No. 3350 upholds this freedom by ensuring that members of certain religious sects are not compelled to join unions against their beliefs, thus protecting their liberty to affiliate or not.
• Non-Impairment of Obligation of Contracts — The constitutional prohibition against laws impairing the obligation of contracts is not absolute and must yield to the legitimate exercise of police power by the State to safeguard the vital interests of its people. The Court acknowledged that R.A. No. 3350 impaired the existing closed-shop agreement but deemed this impairment justified as a valid exercise of police power aimed at protecting religious freedom and the right to work, which are matters of public interest.
• Police Power — The inherent power of the State to enact laws to promote the health, morals, order, safety, and general welfare of the people. The Court found that R.A. No. 3350 was enacted in the legitimate exercise of police power to ensure freedom of belief and religion and to prevent discrimination in employment based on religious grounds.
• Establishment Clause and Free Exercise Clause (Freedom of Religion) — The Constitution prohibits laws respecting an establishment of religion or prohibiting the free exercise thereof. The Court ruled that R.A. No. 3350 does not violate the establishment clause because its purpose is secular (protecting employment and religious freedom) and its primary effect neither advances nor inhibits religion; it merely accommodates religious practices. It upholds the free exercise of religion by relieving individuals of a burden imposed by union security agreements that conflicts with their religious scruples.
• No Religious Test Clause — No religious test shall be required for the exercise of civil or political rights. The Court held that R.A. No. 3350 does not impose a religious test because it does not require membership in a particular religion as a qualification for joining or withdrawing from a union; rather, it grants an exemption ipso jure to those whose religious beliefs already prohibit union affiliation, without requiring them to perform any positive act to exercise a right.
• Equal Protection Clause — All persons similarly circumstanced shall be treated alike, both in rights conferred and responsibilities imposed; however, it allows for reasonable classification. The Court found that the classification in R.A. No. 3350 (exempting members of religious sects prohibiting union affiliation) is valid because it is based on substantial distinctions (differences in religious beliefs), is germane to the purpose of the law (protecting religious freedom and the right to work), is not limited to existing conditions, and applies equally to all members of the designated class.
• Social Justice — The promotion of the welfare of all the people, the adoption by the Government of measures calculated to ensure economic stability of all component elements of society. The Court held that R.A. No. 3350 promotes social justice by protecting the welfare of workers whose religious beliefs prevent union membership, ensuring their right to work and livelihood, and promoting economic stability and equilibrium.
• Judicial Restraint (Wisdom of Laws) — Courts are not concerned with the wisdom, justice, policy, or expediency of a statute; these are matters for the legislature. The Court invoked this to state that the necessity or desirability of R.A. No. 3350 is not a basis for declaring it unconstitutional.

• "It is clear, therefore, that the right to join a union includes the right to abstain from joining any union."
• "Republic Act No. 3350 merely excludes ipso jure from the application and coverage of the closed shop agreement the employees belonging to any religious sects which prohibit affiliation of their members with any labor organization."
• "It should not be overlooked, however, that the prohibition to impair the obligation of contracts is not absolute and unqualified... The contract clause of the Constitution must, therefore, be not only in harmony with, but also in subordination to, in appropriate instances, the reserved power of the state to safeguard the vital interests of the people."
• "It may not be amiss to point out here that the free exercise of religious profession or belief is superior to contract rights. In case of conflict, the latter must, therefore, yield to the former."
• "The purpose of Republic Act No. 3350 is secular, worldly, and temporal, not spiritual or religious or holy and eternal. It was intended to serve the secular purpose of advancing the constitutional right to the free exercise of religion..."
• "The equal protection of the laws clause of the Constitution allows classification... All that is required of a valid classification is that it be reasonable, which means that the classification should be based on substantial distinctions which make for real differences; that it must be germane to the purpose of the law; that it must not be limited to existing conditions only; and that it must apply equally to each member of the class."
• "Social justice guarantees equality of opportunity, and this is precisely what Republic Act No. 3350 proposes to accomplish – it gives laborers, irrespective of their religious scruples, equal opportunity for work."

• Aglipay vs. Ruiz — Referenced to support the principle that the government should not be precluded from pursuing valid secular objectives even if an incidental result is favorable to a religion or sect, and that a statute, to be constitutional, must have a secular legislative purpose and a primary effect that neither advances nor inhibits religion.
• Abo, et al. vs. PHILAME (KG) Employees & Workers Union, et al. — Cited (quoting Rothenberg, Labor Relations) in relation to the principle that the right to join a union includes the right to abstain from joining any union.
• Ilusorio, et al. vs. Court of Agrarian Relations, et al.; Ongsiako vs. Gamboa, et al. — Cited to support the declaration that the prohibition against impairing contract obligations has no application to statutes relating to public subjects within the domain of general legislative powers involving public welfare.
• Asia Bed Factory vs. National Bed and Kapok Industries Workers' Union — Cited in relation to the Blue Sunday Law not being an infringement of contract obligations, as it was enacted for the well-being of the laboring class and was a legitimate exercise of police power.
• People vs. Vera — Cited for the requirements of a valid classification under the equal protection clause: based on substantial distinctions, germane to the purpose of the law, not limited to existing conditions, and applicable equally to all members of the class.
• Calalang vs. Williams — Cited for the definition of social justice as promoting the welfare of all people and ensuring economic stability through proper equilibrium in community inter-relations.
• Guido vs. Rural Progress Administration — Cited to explain that social justice guarantees equality of opportunity.
• Seno vs. Mendoza — Cited in defining "labor dispute" under Section 2(j) of R.A. No. 875 as including questions involving tenure of employment.

• Republic Act No. 875 (Industrial Peace Act), Section 4(a), paragraph 4 — This section, prior to amendment, allowed closed shop agreements. R.A. No. 3350 amended this by adding a proviso exempting members of certain religious sects. Its interpretation and the constitutionality of its amendment were central to the case.
• Republic Act No. 3350 — This is the amendatory act itself, the constitutionality of which was the main issue. It exempts members of religious sects prohibiting affiliation with labor organizations from closed shop agreements.
• Constitution of the Philippines (1935), Article III, Section 1(6) (Freedom of Association) — Guarantees the right to form associations. The Court held R.A. No. 3350 does not violate this but rather upholds it by including the right not to join.
• Constitution of the Philippines (1935), Article III, Section 1(7) (Freedom of Religion, No Religious Test) — Prohibits laws respecting an establishment of religion, or prohibiting its free exercise, and religious tests. The Court found R.A. No. 3350 consistent with these provisions.
• Constitution of the Philippines (1935), Article III, Section 1 (Equal Protection Clause) — Forbids denial of equal protection of the laws. The Court held R.A. No. 3350's classification was reasonable and did not violate this clause.
• Constitution of the Philippines (1935), (Promotion of Social Justice) — The Court found R.A. No. 3350 consistent with this principle. (Specific article not numbered in this part of the text, but generally Article II, Section 5 of the 1935 Constitution).
• Constitution of the Philippines (1973), Article IV, Section 7 (Freedom of Association) — Mentioned as the counterpart to the 1935 provision.
• Constitution of the Philippines (1973), Article IV, Section 8 (Freedom of Religion, No Religious Test) — Mentioned as the counterpart to the 1935 provision.
• Constitution of the Philippines (1935), Article XIV, Section 6 (Protection to Labor) — Enjoins the state to afford protection to labor. Referenced to show the secular purpose of R.A. 3350 in protecting the right to work.
• Constitution of the Philippines (1973), Article II, Section 9 (Protection to Labor) — Mandates state protection to labor, promotion of full employment, and equality in employment. Referenced to further support the secular purpose of R.A. 3350.
• Republic Act No. 875, Section 3 — Provides that employees shall have the right to self-organization and to form, join or assist labor organizations. The Court interpreted this to include the right to refrain from joining.
• Republic Act No. 875, Section 24 — Provides immunity for labor organizations from suits for acts done in furtherance of an industrial dispute under certain conditions. The Court found this inapplicable as the Union's act was the dispute itself.
• Republic Act No. 875, Section 2(j) — Defines "labor dispute." Used to establish that a question involving tenure of employment is a labor dispute.
• Civil Code, Article 1700 — States that relations between capital and labor are not merely contractual but impressed with public interest and must yield to the common good. Used to support the idea that labor contracts can be modified by police power.
• Civil Code, Article 2208 — Allows for the award of attorney's fees when the defendant's act has compelled the plaintiff to incur expenses to protect his interest, or in other cases deemed just and equitable. This was the basis for upholding the award of attorney's fees.
• Rules of Court, Rule 142, Section 1 — States that costs shall be allowed as a matter of course to the prevailing party. Mentioned in relation to the award of costs.

• Justice Fernando — Concurred fully with Justice Zaldivar's opinion, emphasizing the transcendent character of religious freedom and its primacy even over the constitutional principle of protection to labor. He highlighted that religious freedom involves the liberty to worship or not, and to act according to one's creed. He agreed that a closed shop is inherently coercive and that R.A. 3350, by curtailing its operation for religious objectors, follows sound public policy and constitutional tradition. He viewed the right to determine for oneself whether to join a labor organization as an aspect of freedom of association.