c. National Union or Federation; Trade Union Center

Supervisor and Rank and File Union Affiliation

The rank and file union and the supervisors’ union operating within the same establishment may join the same federation or national union [Art. 255].

Note also: Prior to RA 9481’s amendment of Art. 255 [245] expressly allowing both unions to join the same federation or national union, the Court held in De La Salle University v. Laguesma that a local supervisors’ union is not allowed to affiliate with a national federation of unions of rank and file employees only where two conditions concur:

• The rank-and-file employees are directly under the authority of supervisory employees
• The national federation is actively involved in union activities in the company [De La Salle University Medical Center and College of Medicine v. Laguesma, G.R. No. 102084 (1998)].