Title
Brotherhood Labor Unity Movement of the Philippines vs. Zamora
Case
G.R. No. L-48645
Decision Date
Jan 7, 1987
Workers at SMC's glass factory, dismissed for union activities, were ruled as regular employees entitled to reinstatement and backwages, affirming employer-employee relationship.
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Case Digest (G.R. No. L-48645)

Facts:

  1. Background of the Case:

    • Petitioners are members of the "Brotherhood Labor Unity Movement of the Philippines" (BLUM).
    • They filed a complaint against San Miguel Corporation (SMC) and its officers for unfair labor practice and illegal dismissal.
    • The complaint alleged that SMC ordered petitioners to disaffiliate from the union and dismissed them for insisting on union membership.
  2. Nature of Petitioners' Work:

    • Petitioners worked as "cargadores" or "pahinantes" at SMC's Parola Glass Factory since 1961.
    • Their duties included loading, unloading, piling, and palleting empty bottles and wooden shells.
    • They were issued gate passes, provided tools and equipment by SMC, and received job orders from SMC's Superintendent-in-Charge, Enrique Camahort.
    • Work was irregular and paid on a piece-rate basis, with group leaders distributing wages.
  3. Union Activities and Dismissal:

    • In January 1969, petitioners organized and affiliated with BLUM.
    • They demanded overtime pay, holiday pay, and other benefits, but their grievances were ignored.
    • On February 6, 1969, BLUM filed a notice of strike after some members were dismissed for union activities.
    • On February 20, 1969, all petitioners were dismissed and denied entry to the factory.
  4. Legal Proceedings:

    • The case was initially filed with the Court of Industrial Relations (CIR) and later transferred to the National Labor Relations Commission (NLRC).
    • The Labor Arbiter and NLRC ruled in favor of petitioners, but the Secretary of Labor reversed the decision, citing the absence of an employer-employee relationship.

Issue:

  1. Primary Issue:

    • Whether an employer-employee relationship existed between petitioners and SMC.
  2. Subsidiary Issues:

    • Whether petitioners were illegally dismissed.
    • Whether SMC committed unfair labor practice by refusing to bargain with BLUM.

Ruling:

  1. Existence of Employer-Employee Relationship:

    • The Supreme Court ruled that an employer-employee relationship existed between petitioners and SMC.
    • The "control test" was applied, showing that SMC controlled the means and methods of petitioners' work, including discipline and supervision.
  2. Illegal Dismissal:

    • Petitioners were illegally dismissed as their termination was not due to legitimate retrenchment but was a ploy to eliminate union members.
    • The shutdown of the glass plant was temporary, and new workers were hired after repairs.
  3. Unfair Labor Practice:

    • SMC's refusal to bargain with BLUM was not unfair labor practice because SMC already had a collective bargaining agreement with another union (IBM) recognized as the sole bargaining representative.
  4. Relief Granted:

    • SMC was ordered to reinstate petitioners with three years of backwages.
    • If reinstatement was no longer possible, SMC was ordered to pay separation pay equivalent to one month's salary for every year of service.

Ratio:

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