Case Digest (G.R. No. L-48645)
Facts:
The case involves the Brotherhood Labor Unity Movement of the Philippines (BLUM) and several of its members, including Antonio Casbadillo, Prospero Tablada, Ernesto Bengson, and others, as petitioners against various respondents, including Hon. Ronaldo B. Zamora, the Presidential Assistant for Legal Affairs, and San Miguel Corporation, among others. The events leading to this case began on July 11, 1969, when BLUM filed a complaint with the now-defunct Court of Industrial Relations against San Miguel Corporation and several of its officers for unfair labor practices and illegal dismissal. The petitioners alleged that they were ordered to disaffiliate from the union and subsequently dismissed for insisting on their union membership. The respondents contended that the petitioners were not employees of San Miguel Corporation but rather employees of an independent contractor, thus denying any employer-employee relationship.
The case was initially heard by the Court of Industri...
Case Digest (G.R. No. L-48645)
Facts:
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.
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.
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.
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:
Primary Issue:
- Whether an employer-employee relationship existed between petitioners and SMC.
Subsidiary Issues:
- Whether petitioners were illegally dismissed.
- Whether SMC committed unfair labor practice by refusing to bargain with BLUM.
Ruling:
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.
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.
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.
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:
- (Unlock)