Facts:

The case involves Bulakena Restaurant & Caterer and/or Consuelo S. de Garcia as petitioners against the Court of Industrial Relations and the United Employees Welfare Association (UEWA) as respondents. The events leading to this case began in January 1956 when the UEWA was organized among the workers of Bulakena Restaurant, located at 2102 Dewey Boulevard, Pasay City. On January 26, 1956, six members of the union formally affiliated with it. Shortly thereafter, on January 31, 1956, a grievance letter was sent to the management, signed by over sixty employees, including the six complainants. The letter detailed various employment grievances, including the collection of tips, fines for minor infractions, and requests for differential and overtime pay.

On February 14, 1956, the union's supreme head forwarded this grievance to Mrs. Consuelo S. de Garcia, the owner and manager of Bulakena. Subsequently, on April 11, 1956, the union filed a petition for a certification el...

Facts:

1. Union Formation and Grievances:

   • The United Employees Welfare Association (UEWA) was registered with the Department of Labor on February 26, 1954, and organized among the workers of Bulakena Restaurant & Caterer in January 1956.
   • On January 31, 1956, over 60 employees, including six complaining members, submitted a grievance letter to the union's supreme head, Higino H. Mangiliman, highlighting issues such as unfair deductions from tips, excessive fines, unpaid differential and overtime pay, and the demand for union recognition and collective bargaining.

2. Union Recognition and Certification Election:

   • The union sought recognition from the management, but no action was taken. On April 11, 1956, the union filed a petition for a certification election (Case No. 359-MC) to determine its majority status.

3. Dismissal of Union Members:

   • Between May 24, 1956, and August 24, 1956, the six complaining members were dismissed from service. They alleged that their dismissals were due to their refusal to disaffiliate from the union, as demanded by the owner-manager, Mrs. Consuelo S. de Garcia.

4. Unfair Labor Practice Charge:

   • The union filed an unfair labor practice case (Case No. 1265-ULP) against Bulakena Restaurant & Caterer, alleging that the dismissals were motivated by anti-union animus.

5. Employer's Defense:

   • The employer claimed that the dismissals were for just causes, citing various infractions and misconduct by the employees. However, the Court of Industrial Relations found that the dismissals were primarily due to the employees' union membership and activities.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Certification Proceedings:

   • Certification proceedings are non-adversarial and fact-finding in nature. They do not determine the legality of dismissals or employment status, which must be addressed in separate unfair labor practice cases.

2. Res Judicata:

   • For res judicata to apply, there must be identity of parties, subject matter, and causes of action. Since the earlier case involved different employees and factual circumstances, the principle did not apply.

3. Unfair Labor Practice:

   • Dismissals motivated by anti-union animus violate the Industrial Peace Act. The Court found substantial evidence that the dismissals were due to the employees' union membership and activities.

4. Backwages:

   • The award of backwages is not limited to six months unless there are special equitable circumstances, such as a change in ownership or cessation of operations. Since no such circumstances existed, the full award of backwages was justified.