Case Digest (G.R. No. 78604)
Facts:
The case involves Bataan Shipyard and Engineering Co., Inc. (BASECO) as the petitioner and the National Labor Relations Commission (NLRC), along with Hon. Francisco Jose, Jr., Hon. Vladimir P. L. Sampang, Jose G. Cruz, and the National Federation of Labor Unions (NAFLU) as respondents. The events leading to this case began when BASECO, a corporate entity based in Port Area, Manila, applied for the retrenchment of 285 employees due to significant financial losses that had persisted since 1979. This application was filed with the NLRC and was assigned the docket number NLRC Case No. RABIII-2-536-82. During this period, several employees who were on sick leave were also considered retrenched, all of whom were members or officers of NAFLU, a labor organization registered with the Department of Labor and Employment. NAFLU opposed the retrenchment application, representing the affected employees, who subsequently joined the case as individual complainants.
On January 30, 1984, t...
Case Digest (G.R. No. 78604)
Facts:
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.
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.
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.
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.
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.
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:
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Ruling:
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Ratio:
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.
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.
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.
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.