Facts:

The case involves Alabang Country Club, Inc. (the Petitioner) and the National Labor Relations Commission (NLRC), along with the Alabang Country Club Independent Employees Union and three of its former officers: Christopher Pizarro, Michael Braza, and Nolasco Castueras (the Respondents). The events leading to the case began in April 1996 when Pizarro, Braza, and Castueras were elected as Union President, Vice-President, and Treasurer, respectively. On June 21, 1999, the Club and the Union entered into a Collective Bargaining Agreement (CBA) that included provisions for a union shop and maintenance of membership. The CBA stipulated that all regular rank-and-file employees must maintain their union membership as a condition of employment.

In July 2001, a new set of Union officers was elected, who subsequently conducted an audit of the Union's funds. They discovered discrepancies and unaccounted expenses, prompting the Union to request explanations from the three responden...

Facts:

Background of the Parties

• Petitioner: Alabang Country Club, Inc. (Club), a domestic non-profit corporation.
• Respondents:
  • Alabang Country Club Independent Employees Union (Union), the exclusive bargaining agent of the Club's rank-and-file employees.
  • Christopher Pizarro, Michael Braza, and Nolasco Castueras, who were elected Union President, Vice-President, and Treasurer, respectively, in April 1996.

Collective Bargaining Agreement (CBA)

• On June 21, 1999, the Club and the Union entered into a CBA, which included a Union shop and maintenance of membership shop provision.
• Article II, Section 1 of the CBA required all regular rank-and-file employees to maintain their membership in good standing as a condition for continued employment.
• Article II, Section 4 allowed the Club to dismiss employees upon written demand from the Union for various grounds, including malversation of union funds.

Union Audit and Expulsion

• In July 2001, a new set of Union officers conducted an audit and discovered irregularities in the Union funds, including unaccounted expenses and uncollected loans.
• Respondents Pizarro, Braza, and Castueras were asked to explain the discrepancies. They provided explanations, but the Union expelled them on October 16, 2001, for malversation of Union funds.
• The Union then demanded the Club to dismiss the respondents based on the CBA's Union security clause.

Club's Investigation and Termination

• The Club required the respondents to explain why they should not be dismissed. After reviewing their explanations and conducting an informal conference, the Club terminated their employment on December 26, 2001.

Labor Dispute

• The respondents filed an illegal dismissal complaint with the National Labor Relations Commission (NLRC). The Labor Arbiter ruled in favor of the Club, but the NLRC reversed the decision, declaring the dismissal illegal and ordering reinstatement with backwages.
• The Club filed a Petition for Certiorari with the Court of Appeals (CA), which upheld the NLRC's decision, finding that the respondents were deprived of due process.

Issue:

1. Whether there was just cause to dismiss the respondents.
2. Whether the respondents were afforded due process in accordance with the Labor Code and its Implementing Rules.
3. Whether the CA erred in not finding that the NLRC committed grave abuse of discretion.
4. Whether the case of Agabon v. NLRC should be applied.
5. Whether the Union is solely liable for the termination in the absence of bad faith and malice on the part of the Club.

Ruling:

• The Supreme Court reversed the CA and NLRC decisions and reinstated the Labor Arbiter's decision, finding that the respondents were validly dismissed and were afforded due process.
• The Court held that the Club complied with the Union security clause in the CBA and that the respondents were given a reasonable opportunity to be heard before their dismissal.

Ratio:

1. Just Cause for Termination: The respondents were validly dismissed based on the Union security clause in the CBA, which allowed termination upon Union demand for malversation of Union funds. The Club had sufficient evidence to support the Union's decision to expel the respondents.
2. Due Process: The Club substantially complied with due process requirements by notifying the respondents of the charges, allowing them to submit written explanations, and conducting an informal conference before dismissing them.
3. Non-Applicability of Malayang Samahan: The case of Malayang Samahan does not apply here because the Club conducted a separate investigation and afforded the respondents an opportunity to be heard, unlike in Malayang Samahan where no hearing was conducted.
4. Non-Applicability of Agabon: The Agabon doctrine, which allows dismissal for just cause even if due process is lacking, does not apply here because the respondents were afforded due process.
5. Liability of the Union: The issue of the Union's sole liability is moot since the Court found the dismissal valid.

Conclusion:

The Supreme Court ruled that the respondents were validly dismissed and were afforded due process. The CA and NLRC decisions were reversed, and the Labor Arbiter's decision was reinstated.