Title
Benguet Consolidated, Inc. vs. BCI Employees and Workers Union-PAFLU
Case
G.R. No. L-25471
Decision Date
Mar 27, 1968
Benguet Consolidated, Inc. found guilty of unfair labor practice for discriminating against employee Donaciano Andrada due to his union activities, ordered to retroactively adjust wages.
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Case Digest (G.R. No. L-25471)

Facts:

Background of the Case

  • Parties Involved:
    • Petitioners: Benguet Consolidated, Inc., Stanley Willimont, Eugene Kneebone, C.W. Herold, A.P. Davidson, G.N. Wright, and O.M. Westerfield.
    • Respondents: BCI Employees & Workers Union-PAFLU, Donaciano S. Andrada, and the Court of Industrial Relations.
  • Nature of the Case: Unfair labor practice charge filed by Donaciano Andrada and the union against Benguet Consolidated, Inc., alleging discrimination against Andrada due to his union activities.

Employment and Promotion of Donaciano Andrada

  • Initial Position: Andrada was a payroll clerk with a daily wage of P3.24.
  • Promotion: In 1954, Andrada was promoted to Invoice Processing Clerk (first class) but did not receive the corresponding wage increase as per the collective bargaining agreement (CBA), which stipulated a wage of P3.56 per day for first-class clerks.
  • Transfer: In 1955, Andrada was transferred to the Purchasing Department as a first-class clerk, replacing Ramon Alvia, who had a higher wage of P4.60 per day. Andrada continued to receive his previous wage of P3.24 per day.

Union Activities and Alleged Discrimination

  • Union Involvement: Andrada was an active member of the Benguet-Balatoc Workers Union. He sought the union's assistance to address his wage concerns.
  • Statements by Company Officials:
    • Stanley Willimont allegedly told Andrada that his future would have been better had he not involved the union.
    • Eugene Kneebone reportedly stated that Andrada's vocal union activities were the reason for his unfavorable treatment.
  • General Pay Hike: In July 1962, a general wage increase of P0.24 was implemented, but Andrada did not receive this increase.

Filing of the Complaint

  • Unfair Labor Practice Charge: Filed on May 3, 1963, alleging discrimination against Andrada starting from 1954 due to his union activities.
  • Formal Complaint: Filed on September 4, 1963, by the acting prosecutor of the Court of Industrial Relations.

Lower Court Decision

  • Findings: The Court of Industrial Relations found Benguet Consolidated, Inc., guilty of unfair labor practice for discriminating against Andrada.
  • Order: The company was ordered to implement the proper wage scale for Andrada from 1954 onwards, in accordance with the CBA.

Issue:

  1. Whether the petitioners discriminated against Donaciano Andrada in violation of Section 4(a)(4) of Republic Act 875 (Industrial Peace Act).
  2. Whether the alleged discrimination was due to Andrada's union activities.
  3. Whether the charge of unfair labor practice was barred by laches.
  4. Whether the grievance proceedings had already resolved Andrada's complaint.

Ruling:

The Supreme Court affirmed the decision of the Court of Industrial Relations, holding that:

  • The petitioners were guilty of unfair labor practice for discriminating against Andrada due to his union activities.
  • The discrimination was continuous, starting from 1954 and persisting until 1962.
  • The charge was not barred by laches, as the discrimination was ongoing, and the complaint was filed after conciliation efforts failed.
  • The grievance proceedings did not satisfactorily resolve Andrada's complaint.

Ratio:

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