Facts:

The case in question, Arellano University Employees and Workers Union et al. vs. Court of Appeals et al., originated from a labor dispute involving the Arellano University Employees and Workers Union (the Union), which represents approximately 380 rank-and-file employees of Arellano University, Inc. (the University). The Union filed a Notice of Strike on December 12, 1997, alleging unfair labor practices (ULP) against the University. These allegations included interference in union activities, union busting, and improper contracting out of services. Subsequently, on December 17, 1997, a majority of Union members initiated a petition for an audit of Union funds, further complicating the situation.

On March 11, 1998, the Department of Labor and Employment (DOLE) intervened, directing a general membership meeting to discuss the financial discrepancies. Additionally, Secretary Cresenciano Trajano certified the Notice of Strike for compulsory arbitration to the National Labor Relatio

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Facts:

Procedural Background and Filing of the Petition

• Petitioners filed a petition for certiorari challenging the Court of Appeals resolutions (dated April 13, 1999, and September 3, 1999) which dismissed their petition on the ground that it was filed six days beyond the reglementary period under Section 4, Rule 65 of the 1997 Rules of Civil Procedure.
• The petitioners argued for the application of substantial justice over strict procedural lapses and advocated for a liberal construction of the Rules to achieve a just disposition.
• The timeline shows that the resolution denying their motion for reconsideration was received on September 13, 1999, after which petitioners duly filed for a 30-day extension on September 27, 1999, and finally filed the certiorari petition on October 28, 1999.
• The Court treated the petition as one for review under Rule 45, relying on the retroactive application of the amended Section 4 of Rule 65 as per the Court’s subsequent resolution (A.M. No. 00-2-03-SC, effective September 1, 2000).

Union and Employer Dispute Context

• On December 12, 1997, the Arellano University Employees and Workers Union (the Union) filed a Notice of Strike with the National Conciliation and Mediation Board (NCMB), alleging various forms of Unfair Labor Practices (ULP) by Arellano University, Inc. (the University).
• Allegations included interference in union activities, union busting (specifically, failure to deduct penalties from absent members during union meetings), and the contracting out of work performed by union members.
• On December 17, 1997, a petition for an audit of union funds was filed by a majority of the Union’s members before the Department of Labor and Employment (DOLE) to examine unexplained remittances.
• On March 11, 1998, the DOLE Regional Director directed the union officers to hold a general membership meeting to account for union funds amounting to P481,117.28.

Remedial Proceedings and Consolidation of Cases

• The DOLE Secretary certified the Notice of Strike for compulsory arbitration to the National Labor Relations Commission (NLRC), which then assigned Labor Arbiters to hear the dispute.
• Several hearings were conducted (on July 3, July 17, and August 11, 1998) but did not result in a settlement.
• The University moved to consolidate its cases with other disputes:
• An interpleader filed against the Union and some members, docketed as NLRC NCR Case No. 00-02-02036-98.
• A complaint raised by the Union regarding underpayment of wages (docketed as NLRC NCR Case No. 00-02-01422-98).
• A second Notice of Strike, dated July 16, 1998, was also certified, leading to a strike staged on August 5, 1998.
• The DOLE, via an order on August 5, 1998, directed an immediate return to work, and the strike was lifted on August 7, 1998, at about 3:00 p.m.

NLRC and Related Decisions

• In the NLRC decision dated October 12, 1998, the Union’s notices of strike (NCMB-NCR-NS-12-520-97 and NCMB-NCR-NS-07-277-98) were declared without merit to the extent that they addressed the issues at dispute.
• Consequent rulings included:
• The University being absolved of ULP charges;
• The declaration of loss of employment status of all strikers in NLRC NCR Case No. 00-08-06897-98; and
• Affirmation of the use of 314 days as the divisor in computing the “equivalent daily rate” of workers, rather than 365 days.
• Following the NLRC decision, petitioners filed a motion for reconsideration (denied by Resolution of January 20, 1999) and then elevated the case on certiorari, contesting various aspects of the NLRC and appellate court decisions.

Claims and Relief Sought

• Petitioners contended that the University violated the collective bargaining agreement (CBA) by withholding union dues and death benefits.
• They argued that such withholding was impermissible under the CBA and existing labor laws.
• The University defended its actions by asserting that it had acted on the written request of some union members, consistent with the prevailing rules on check-offs and payroll deductions.
• With respect to the dismissal of certain petitioners (union members participating in the illegal strike), petitioners argued for their reinstatement without backwages or, alternatively, for separation pay of one month’s salary per year of service.
• The dispute over the computation of salaries based on a 314-day divisor, in lieu of a 365-day divisor, was also raised, with the University maintaining that this calculation was in accordance with the “no work, no pay” principle.

Issue:

Retroactive Application of the Amended Procedural Rule

• Should the amended provisions of Section 4 of Rule 65 of the 1997 Rules, allowing an extension from 60 days, be given retroactive effect even though the challenged resolutions were issued in 1999, prior to the amendment?
• Does the granting of the 30-day extension remedy the alleged procedural default?

Substantial Justice Versus Procedural Lapses

• Can the petition be allowed under the principle of substantial justice despite its filing beyond the original reglementary period?
• Is it proper to prioritize the substantive rights and remedies of the union members over strict adherence to procedural deadlines?

Validity of the University's Actions under the Collective Bargaining Agreement (CBA)

• Did the University commit an Unfair Labor Practice by withholding union dues and death benefits, or was such action justified by the written requests of union members?
• Was the refusal to deduct penalties for union meeting absences in breach of the CBA?
• Does the method of computing daily wages using a 314-day divisor constitute a substantial diminution of salary?

Evidentiary Basis for Employment Dismissal

• Was there sufficient evidence to justify the NLRC’s declaration of loss of employment status for the strikers?
• Should the union members who were dismissed be reinstated, or alternatively, awarded separation pay, given the lack of clear evidence proving their knowing participation in illegal acts during the strike?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)