Title
Alhambra Industries, Inc. vs. Court of Industrial Relations
Case
G.R. No. L-22219
Decision Date
Aug 28, 1969
Alhambra Industries, successor to Alhambra Cigar, refused to reinstate employees despite a final CIR order, citing abolished positions. SC upheld reinstatement, emphasizing finality of judgments and labor rights.
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Case Digest (G.R. No. L-22219)

Facts:

  1. Background of the Case:

    • The case involves Alhambra Industries, Inc. (petitioner) and the Kapisanan ng mga Manggagawa sa Alhambra (PAFLU) (respondent Union).
    • The dispute originated from an unfair labor practice case against Alhambra Cigar and Cigarette Manufacturing Co., the predecessor of Alhambra Industries, Inc.
    • On April 3, 1962, the Court of Industrial Relations (CIR) found Alhambra Cigar and Cigarette Manufacturing Co. guilty of unfair labor practice and ordered the reinstatement of five employees: Emiliano Averilla, Maglayon Pangan, Alfredo Roy, Ricardo Bernardino, and Juliana Lapasaran.
  2. Corporate Succession:

    • Alhambra Cigar and Cigarette Manufacturing Co. ceased operations on January 12, 1962, due to the expiration of its corporate life.
    • Alhambra Industries, Inc. was established as its successor.
  3. Execution of the Order:

    • On July 6, 1962, the respondent Union filed a motion for the execution of the April 3, 1962, reinstatement order.
    • Alhambra Cigar and Cigarette Manufacturing Co. opposed the motion, citing its dissolution.
    • On May 30, 1963, the CIR ruled that Alhambra Industries, Inc., as the successor, was liable for reinstatement and back wages.
  4. Petitioner’s Refusal to Comply:

    • Despite the finality of the May 30, 1963, order, Alhambra Industries, Inc. refused to reinstate the employees.
    • On October 9, 1963, the petitioner filed a "Manifestation and Motion" seeking to present evidence that the employees could not be reinstated due to the abolition of their former positions for legitimate business reasons.
  5. CIR’s Order of October 28, 1963:

    • The CIR granted the Union’s motion for reinstatement and computation of back wages.
    • The court ordered the immediate issuance of a writ of execution for reinstatement and directed the Chief Examiner to compute back wages.

Issue:

  1. Primary Issue:

    • Whether the Court of Industrial Relations (CIR) validly refused to receive evidence from Alhambra Industries, Inc. regarding the alleged impossibility of reinstating the employees due to the abolition of their former positions.
  2. Subsidiary Issue:

    • Whether the grounds raised by the petitioner for non-reinstatement were already available and should have been raised during the earlier proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the CIR’s order for reinstatement and payment of back wages, emphasizing the finality of judgments, the binding nature of factual findings by the CIR, and the policies of the Industrial Peace Act. The petitioner’s refusal to comply with the final order was deemed unjustified, and the Court affirmed the CIR’s decision to enforce the reinstatement and back wages.


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