Title
Bataan Shipyard and Engineering Co., Inc. vs. National Labor Relations Commission
Case
G.R. No. 78604
Decision Date
May 9, 1988
BASECO retrenched 285 employees, targeting NAFLU members, citing financial losses. SC upheld NLRC's ruling of unfair labor practice, affirming discriminatory retrenchment and awarding backwages.
Font Size:

Case Digest (G.R. No. 78604)

Facts:

  1. Parties Involved:

    • Petitioner: Bataan Shipyard & Engineering Co., Inc. (BASECO), a corporation based in Port Area, Manila.
    • Respondents: National Labor Relations Commission (NLRC), Hon. Francisco Jose, Jr., Hon. Vladimir P. L. Sampang, Jose G. Cruz, and the National Federation of Labor Unions (NAFLU), a registered labor organization.
  2. Background of the Case:

    • BASECO filed an application with the NLRC for the retrenchment of 285 employees, citing heavy financial losses since 1979. The case was docketed as NLRC Case No. RABIII-2-536-82.
    • Some employees on sick leave were retrenched, all of whom were officers and members of NAFLU.
    • NAFLU opposed the retrenchment on behalf of the affected employees, who joined the case as individual complainants.
  3. Labor Arbiter's Decision:

    • On January 30, 1984, the Executive Labor Arbiter ruled the retrenchment valid but found BASECO guilty of unfair labor practice for discriminating against NAFLU members. BASECO was ordered to pay separation benefits and six months' backwages to the retrenched employees.
  4. NLRC Resolution:

    • On December 27, 1985, the NLRC affirmed the Labor Arbiter's decision, noting BASECO's failure to explain why only NAFLU members were retrenched.
  5. Petition to the Supreme Court:

    • BASECO filed a Petition for Certiorari on June 10, 1987, challenging the NLRC's finding of unfair labor practice and the award of backwages.
  6. Solicitor General's Comment:

    • The Solicitor General supported the NLRC's decision, arguing that while the retrenchment was valid, the manner of implementation was discriminatory and constituted unfair labor practice.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Validity of Retrenchment:

    • The Court acknowledged that BASECO's retrenchment was valid due to financial losses. However, the manner of implementation must be free from abuse of discretion.
  2. Unfair Labor Practice:

    • The Court found that BASECO's retrenchment was discriminatory because all retrenched employees were NAFLU members. The absence of clear guidelines for selecting employees for retrenchment reinforced this finding.
    • Under Article 249 of the Labor Code, interfering with employees' right to self-organization constitutes unfair labor practice.
  3. Due Process and Abuse of Discretion:

    • The Court emphasized that while employers have the right to retrench employees, this right must be exercised without oppression or abuse. The NLRC did not commit grave abuse of discretion in its ruling.
  4. Substantial Evidence:

    • The Court agreed with the Solicitor General that the NLRC's findings were supported by substantial evidence, particularly the lack of justification for retrenching only NAFLU members.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.