Case Digest (G.R. No. 151021) Core Legal Reasoning Model
Facts:
This case involves Cainta Catholic School (the petitioner) and the Cainta Catholic School Employees Union (CCSEU) (the respondent), with Msgr. Mariano T. Balbago serving as School Director. On March 6, 1986, the School and the Union entered into a Collective Bargaining Agreement (CBA) effective from January 1, 1986, to May 31, 1989. The CBA included a retirement provision authorizing the School to retire employees who reached 60 years of age or rendered at least 20 years of service (with the last three years continuous) (Article X, Section 2). Msgr. Balbago was appointed as School Director in April 1987, which coincided with the Union becoming inactive until it reactivated on September 10, 1993. Following the reactivation, the Union elected Mrs. Rosalina Llagas as President and Paz Javier as Vice-President.
On October 15, 1993, the School retired Llagas and Javier, who had rendered more than 20 years of service but were not yet at the compulsory retirement age, invoking the CBA
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Case Digest (G.R. No. 151021) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Case
- Petitioners: Cainta Catholic School and Msgr. Mariano T. Balbago (School and School Director).
- Respondent: Cainta Catholic School Employees Union (Union).
- Central issue: Validity of a stipulation in a Collective Bargaining Agreement (CBA) allowing management to retire an employee before reaching the mandatory retirement age under the Labor Code.
- Case history: The NLRC ruled in favor of the School; the Court of Appeals reversed; the petitioners elevated the case to the Supreme Court via petition for review on certiorari.
- Background and CBA Provisions
- On 6 March 1986, a CBA was agreed between the School and the Union effective until 31 May 1989, with provisions including:
- Article IX on Duration allowing provisions to remain in effect until a new agreement is executed.
- Article X, Section 2: Employees may be retired upon reaching 60 years old or after 20 years of service with at least the last 3 years continuous.
- Msgr. Mariano Balbago appointed School Director in April 1987; the Union became inactive until it was reactivated with new officers elected on 10 September 1993.
- On 15 October 1993, the School retired two union officers, Llagas (President) and Javier (Vice-President), who both had over 20 years of continuous service but were below 60 years of age, relying on the CBA provision on retirement.
- Union’s Response and Labor Proceedings
- The Union swiftly filed a notice of strike, and on 8 November 1993, commenced picketing the school.
- The Secretary of Labor certified the labor dispute to the NLRC and ordered the suspension of Llagas and Javier’s termination, and reinstatement pending the case’s resolution.
- The School filed a petition declaring the strike illegal; the Union filed an unfair labor practice complaint.
- The cases were consolidated.
- Decisions Below
- NLRC (31 January 1997): Found retirement legal pursuant to CBA, dismissed the unfair labor practice charge due to insufficient evidence, declared the strike illegal, and declared union officers who struck to have lost employment status.
- Court of Appeals (20 August 2001): Reversed NLRC, ruling that the retirement was an unfair labor practice intended to “bust” the reactivated union, declared the strike legal, and ordered reinstatements and payment of damages to certain union officers including Llagas and Javier’s heirs; denied petition for contempt.
- The School filed a petition for review before the Supreme Court.
- Additional Facts Regarding Employees’ Status
- Llagas held the position of Dean of Student Affairs performing managerial functions.
- Javier was Subject Area Coordinator with supervisory functions recommending hiring, termination and disciplinary actions.
- The NLRC found Llagas as a managerial employee and Javier as a supervisory employee, thus disqualifying them from union membership or limiting the union’s representation capacity.
Issues:
- Whether the School’s decision to retire Llagas and Javier pursuant to the CBA constitutes unfair labor practice.
- Whether the strike initiated by the Union is legal.
- Whether some union officers who were ordered dismissed are entitled to back wages.
- Whether Llagas and Javier were managerial and supervisory employees disqualifying them from union membership and hence affecting the legitimacy of the strike.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)