Facts:

In the case of P. A. Almira et al. vs. B. F. Goodrich Philippines, Inc., filed as G.R. No. L-34974, the petitioners, comprising numerous employees, contested the legality of a strike declared illegal by the Court of Industrial Relations (CIR) on February 4, 1972. The events stemmed from a contentious labor dispute involving the private respondent, B. F. Goodrich Philippines, Inc., occurring in their facilities located in Makati and Marikina, Rizal. The petitioners engaged in a strike that included mass picketing, during which unlawful acts were reportedly committed, such as preventing access to company premises by non-striking employees and customers.

In response to the striking activities, the management published notices in prominent newspapers on April 23, 1971, instructing employees not participating in the strike to report for work, signaling that failure to do so would be considered participation in the illegal strike. The strike escalated, marked by incidents of violence

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Facts:

Background and Context

• The dispute arose from a labor-management conflict at B. K. Goodrich Philippines, Inc., characterized by long-standing bitterness between the parties.
• Petitioners (the striking employees) were involved in a strike whose conduct and means were intensely scrutinized by the respondent Court of Industrial Relations.
• The strained relations and mutual accusations of reprehensible conduct set the stage for an emotionally charged confrontation.

The Strike and Its Conduct

• The strike involved mass picketing at the complainant’s premises in Makati and Marikina, Rizal.
• Respondents (striking employees) were observed blocking and preventing the entry of customers, supplies, and non-striking employees.
• Acts of violence, including physical altercations and injuries, were reported.
• The picketing was marked by repeated incidents that escalated the dispute:
• Several instances of physical violence and intimidation were recorded during the picketing.
• Specific acts mentioned include the infliction of injuries on complainant’s personnel and the setting on fire of the Makati Recap Plant’s roof.

Management’s Counter-Responses

• The complainant undertook measures to counteract the strike:
• Notices were published in widely circulated newspapers (Manila Times and Daily Mirror) instructing non-striking employees to report for work.
• These notices were accompanied by explicit instructions on how to ensure safety amidst the disorder.
• Despite these measures, some respondents initially failed to report for work and were later seen re-engaging in picketing, thus compounding the controversy.

Judicial Findings and Order of the Lower Court

• Respondent Judge Joaquin Salvador, in his order dated February 4, 1972, found that:
• The respondents’ actions during the strike constituted an illegal strike, as they employed coercive and violent means.
• The illegality was affirmed based on the pattern of violence and intimidation observed during the strike.
• As a consequence, the order declared that petitioners lost their status as employees of the company effective April 19, 1971.

Prior Jurisprudence and Legal Perspectives Cited

• The decision noted previous cases such as:
• Cebu Portland Cement Co. v. Cement Workers Union, which influenced the understanding of the right to strike and its boundaries.
• Shell Oil Workers’ Union v. Shell Company of the Philippines, Ltd., where the court cautioned against automatic imposition of illegality solely based on violent acts.
• These precedents underscored that while violence during a strike is condemnable, it does not necessarily justify automatic dismissal without a careful, context-sensitive application of the law.

Contextual and Equitable Considerations

• Emphasis was placed on the constitutional guarantee of security of tenure, highlighting the need for more measured and proportionate responses.
• The factual record pointed to a situation where both parties contributed to the escalation of violence, thereby complicating the issue of assigning sole responsibility for unlawful conduct.

Issue:

Determination of Illegality in the Context of a Violent Strike

• Whether the respondent Court was justified in declaring the strike illegal solely on the basis of the coercive means and violent picketing.
• To what extent the use of force and intimidation, though present, warranted a collective imputation of illegality.

Appropriateness of Automatic Termination of Employment

• Whether the dismissal of the petitioners, resulting in the loss of their employment status, was an inevitable consequence given the circumstances.
• The proper balance between enforcing disciplinary measures and upholding the constitutional right to security of tenure.

The Role of Precedent in Shaping the Disposition

• If and how prior decisions (e.g., Cebu Portland Cement and Shell Oil Workers’ Union cases) should have mitigated the severe penal measures imposed.
• Whether similar instances of violence in labor disputes have been treated differently in past jurisprudence.

Evaluation of Conduct Amidst Mutual Violence

• How to apportion responsibility when both the labor and management were involved in activities that escalated the conflict.
• Determining whether a less condemnatory stance on the use of coercive measures could have prevented the drastic outcome.

Ruling:

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Ratio:

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Doctrine:

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