Facts:

The case involves two consolidated petitions filed by Bagong Pagkakaisa ng Manggagawa ng Triumph International, represented by its President Sabino F. Graganza, and Triumph International (Phils.), Inc. The petitions arose from a labor dispute concerning the expiration of their collective bargaining agreement (CBA) on July 18, 1999, and the subsequent negotiation deadlock over wage increases. The union proposed a wage increase of P180.00 over three years, while the company initially offered P42.00, later raising it to P45.00. Following failed negotiations, the union filed a Notice of Strike on October 15, 1999. In response, on November 15, 1999, Triumph International filed a Notice of Lockout, alleging unfair labor practices. The union commenced a strike on November 18, 1999. The Secretary of Labor of the Department of Labor and Employment (DOLE) assumed jurisdiction over the labor dispute on January 27, 2000, directing the striking workers to return to work. The union, however,

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Facts:

Background of the Dispute

• The dispute involved the collective bargaining relationship between the Bagong Pagkakaisa ng Manggagawa ng Triumph International (the union) and Triumph International (Phils.), Inc. (the company).
• The parties had a collective bargaining agreement (CBA) that expired on July 18, 1999, prompting the union to submit wage and other economic proposals for renegotiation.

Negotiations and Breakdown

• The union proposed an economic demand for a wage increase of P180.00 per day, spread over three years—with incremental increases breaking down as P70.00/day starting July 19, 1999; P60.00/day from July 19, 2000; and P50.00/day from July 19, 2001.
• The company countered with a lower wage increase offer which was initially P42.00/day, later modified to P45.00/day for three years.
• The negotiations reached an impasse, leading the union to file a Notice of Strike on October 15, 1999.

Escalation to Strike and Lock-out

• Following the union’s strike notice, the National Conciliation and Mediation Board (NCMB) attempted to mediate but failed to resolve the deadlock.
• On November 15, 1999, the company filed a Notice of Lock-out alleging unfair labor practices, including a work slowdown by the union.
• The union commenced strike action on November 18, 1999.

Government Intervention and Orders

• On January 27, 2000, Secretary Bienvenido E. Laguesma of the Department of Labor and Employment (DOLE) assumed jurisdiction over the dispute pursuant to Article 263(g) of the Labor Code.
• The Labor Secretary issued orders directing all striking workers to return to work within 24 hours under the pre-strike terms and conditions, and he required that both parties submit their position papers.
• Despite initial attempts by some employees to report to work in early February 2000, union members blocked their entry into company premises, prompting further interventions and additional return-to-work orders on February 22, 2000, and subsequent conciliation meetings.

Dismissal of Union Officers

• Although the union board advised a return to work effective March 3, 2000, the company excluded twenty union officers and a shop steward by issuing identical letters demanding written explanations for defying the orders.
• The union officers were charged with defiance of the Labor Secretary’s orders, participating in an illegal work slowdown during the deadlocked CBA negotiations, and obstructing returning employees.
• A hearing was conducted on May 5, 2000, after which the union officers were served notices of termination effective May 11, 2000.
• Later developments included motions by the union for reinstatement and petitions urging the citation of the company for contempt, while the company filed motions for the annulment of decisions related to the dismissal issue.

Judicial and Administrative Proceedings

• The union elevated the case to the Court of Appeals (CA) through a petition for certiorari, challenging both the wage increase award rendered by the Labor Secretary and the dismissal of its officers.
• Concurrently, Triumph International (Phils.), Inc. filed its own petition seeking the annulment of the CA decision on the dismissal issue.
• During the pendency of the petitions, individual settlements were reached by some petitioners who executed Release, Waiver, and Quitclaim agreements.

Consolidated Issues from the CA Decision

• The CA upheld the Labor Secretary’s wage award of P48.00 per day over three years, based on prevailing economic indicators and industry comparisons.
• The CA modified the Labor Secretary’s ruling on the dismissal issue, determining that while the dismissal of most union officers (for failure to comply with return-to-work orders, participation in the illegal slowdown, and related acts) was illegal due to lack of substantial evidence, the dismissal of union officer Reyvilosa Trinidad was upheld as valid.

Issue:

Validity and Reasonableness of the Wage Award

• Whether the award of a wage increase of P48.00 per day, distributed over three years as rendered by the Labor Secretary, was justified given economic conditions, industry standards, and the company’s capacity to pay.
• Whether historical wage adjustments and the company’s financial performance should have been given more weight in determining the appropriate wage increase.

Legality of the Dismissal of Union Officers

• Determining whether the dismissal of union officers and a shop steward, particularly the case of Reyvilosa Trinidad versus the other officers, was made with valid and just cause.
• Evaluating whether the union’s defiance of the Labor Secretary’s return-to-work orders and participation in an illegal strike and work slowdown justified dismissal under Article 264(a) of the Labor Code.

Jurisdictional Concerns

• Whether the Labor Secretary’s assumption of jurisdiction under Article 263(g) extended to resolving controversies related to dismissal, a matter also claimed to be under the exclusive jurisdiction of the labor arbiter pursuant to Article 217 of the Labor Code.
• Whether the Court of Appeals exceeded its certiorari jurisdiction by addressing the merits of the dismissal issue instead of strictly confining itself to jurisdictional errors.

Procedural Fairness and Due Process

• Whether the parties, particularly the company, were deprived of the right to present evidence and due process when the presentation and resolution of the dismissal issue was undertaken by the CA.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)