Case Digest (G.R. No. L-24711)
Facts:
In Benguet Consolidated, Inc. v. BCI Employees & Workers Union-PAFLU et al. (131 Phil. 994, April 30, 1968), the plaintiff-appellant, Benguet Consolidated, Inc. (BENGUET), operated gold mines and milling plants at Balatoc, Antamok and Acupan in Itogon, Mountain Province. On June 23, 1959, the Benguet-Balatoc Workers Union (BBWU) executed a four-and-a-half-year collective bargaining contract with BENGUET that included a No-Strike, No-Lockout clause. After a certification election on April 6, 1962, the BCI Employees & Workers Union (UNION), affiliated with the Philippine Association of Free Labor Unions (PAFLU), was certified on August 18, 1962 as the exclusive bargaining agent. UNION members voted on November 22–24, 1962 to strike over alleged unfair labor practices and filed a Notice of Strike on December 28, 1962. On March 2, 1963, UNION members formed picket lines, allegedly employing threats and violence to halt operations and restrict entry. The conflict ended in a May 2, 19Case Digest (G.R. No. L-24711)
Facts:
- Collective Bargaining Agreement (CBA)
- On June 23, 1959, Benguet Consolidated, Inc. (BENGUET) and the Benguet-Balatoc Workers Union (BBWU) executed a CBA effective June 23, 1959 to December 23, 1963, containing a No-Strike, No-Lockout clause.
- The CBA covered all BENGUET employees in its Balatoc, Antamok, and Acupan mines and milling establishments.
- Change of bargaining agent
- On April 6, 1962, the Department of Labor conducted a certification election among BENGUET rank-and-file employees; BCI Employees & Workers Union (UNION) secured over 50% of votes.
- On August 18, 1962, the Court of Industrial Relations (CIR) certified UNION as sole and exclusive bargaining agent for wages, hours, and other conditions of employment.
- Strike and aftermath
- In late November 1962, UNION members approved a resolution to strike for grievances including refusal to grant living allowances, disciplinary issues, and discrimination. Notice of strike was filed December 28, 1962.
- On March 2, 1963, UNION members struck and formed picket lines; incidents of threats and limited violence occurred, leading to criminal prosecutions for coercion. Work stopped; two weeks later, limited maintenance was allowed.
- On May 2, 1963, BENGUET and UNION executed a return-to-work agreement; January 29, 1964, a new CBA was finally signed.
- Civil action and lower court decision
- BENGUET sued UNION, PAFLU, and their presidents in Manila CFI for P1,911,363.83 as damages for breach of the No-Strike clause.
- Defendants pleaded: (a) they were not bound by the BBWU-BENGUET CBA; (b) strike due to unfair labor practices; (c) strike lawful under RA 875.
- On February 23, 1965, the trial court dismissed BENGUET’s complaint and denied defendants’ counterclaim, ruling the No-Strike clause did not bind UNION.
Issues:
- Did the June 23, 1959 CBA between BENGUET and BBWU automatically bind UNION-PAFLU upon certification on August 18, 1962?
- Are the defendant labor unions and their officers liable for illegal acts committed during the strike and picketing?
- Are the defendants liable to pay the damages claimed by BENGUET for rehabilitation and losses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)