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At Plant Omega, a BLR Regional Office certifies Union Echo as the exclusive bargaining representative for a unit described as all non-managerial employees in the Production divisions across Plants Alpha and Beta, including casual and temporary workers, after a BLR-supervised election. The unit petition had cleared only permanent production workers in both plants and expressly excluded casuals and temps. The Employer challenges the certification before the NLRC, contending that the BLR officer acted beyond the scope of authority by (i) certifying a unit not cleared in the petition and clearance, and (ii) including workers outside the petitioned unit. The certification is relied upon to recognize Union Echo and to begin negotiations, culminating in a collective bargaining agreement that the Employer later contends is void if the certification is invalid. (a) Identify the controlling doctrine governing the BLR official’s authority to certify a bargaining representative. (b) If the BLR official acted beyond the scope of authority, is the BLR bound by the certification under actual, apparent, or implied authority, or by agency by estoppel or ratification? (c) What is the effect on the parties if the certification is later found void or voidable, particularly with respect to the validity and enforceability of the subsequent CBA?

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