Title
Association of Integrated Security Force of Bislig vs. Court of Appeals
Case
G.R. No. 140150
Decision Date
Aug 22, 2005
The Supreme Court upholds the closure of a paper manufacturer's security force and the termination of security guards, dismissing claims of illegal dismissal by a labor organization.
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Case Digest (G.R. No. 140150)

Facts:

  • The case involves the Association of Integrated Security Force of Bislig (AISFB-ALU) as the petitioner and the Court of Appeals and Paper Industries Corporation of the Philippines (PICOP) as the respondents.
  • In 1990, security guards employed by PICOP formed a labor union, AISFB-ALU, which was registered with the Department of Labor and Employment (DOLE).
  • A certification election on May 4, 1990, resulted in ALU-TUCP being declared the exclusive bargaining agent for the security guards.
  • On April 1, 1991, the Philippine Constabulary Civil Security Force Command advised PICOP to cease using its Company Guard Force due to the expiration of its operating license.
  • PICOP issued a memo on April 4, 1991, instructing security personnel to continue their duties until further notice.
  • On April 6, 1991, security guards received termination notices effective May 7, 1991, citing closure due to non-renewal of the operating license, which expired on March 31, 1991.
  • PICOP faced difficulties in renewing the license due to missing firearms and suspicions of rebel sympathies among some security personnel.
  • Security guards filed a notice of strike on April 8, 1991, but did not proceed due to fears of violence; many accepted closure and received separation benefits.
  • The labor dispute was certified to the National Labor Relations Commission (NLRC) for compulsory arbitration, which ruled in favor of PICOP.
  • The Court of Appeals affirmed the NLRC's decision on July 20, 1999, leading the petitioner to file a certiorari petition before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the petition for lack of merit, affirming the decisions of the NLRC and the Court of Appeals.
  • The closure of PICOP's security force and...(Unlock)

Ratio:

  • The Supreme Court stated that the remedy for reversing or modifying a judgment on the merits is through appeal, and the petitioner did not file a motion for reconsideration, which is necessary for a certiorari petition.
  • Certiorari is not a substitute for a lost appeal.
  • The NLRC's ...continue reading

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