G.R. No. L-7496 - Caltex Inc. vs. Katipu Labor Union

On June 24, 1953, the Court of Industrial Relations received a petition by the Katipunan Labor Union concerning the dismissal of employee Florencio Alforque by Caltex (Philippines) Inc.
The petition, dated June 8, 1953 and docketed as Case No. 430-V (1), alleged that Alforque was dismissed without sufficient or valid cause and without an investigation, in violation of a prior order of the Court of Industrial Relations dated March 18, 1950.

The petition was received after the approval of Republic Act No. 875 on June 17, 1953; however, it was mailed before the said approval.
Caltex (Philippines) Inc. filed an answer contesting the allegations, asserting that:

Alforque lacked judgment, initiative, and ability as a mechanic.
There was over-staffing at the branch and his services were unnecessary.
Case No. 430-V had already been terminated before the petition was filed.
The petition did not state sufficient facts to justify the Court’s exercise of jurisdiction.

A labor dispute had arisen in 1950 between the Katipunan Labor Union and Caltex (Philippines) Inc., leading to the docket of case No. 430-V under the title “Caltex Cebu Branch vs. Katipunan Labor Union.”
The dispute was amicably settled on June 29, 1950, with the Court of Industrial Relations approving the settlement on July 28, 1950.
One of the key terms of the settlement was that before any dismissal, lay-off, or suspension, the company would give the union the opportunity to be heard, providing no less than three (3) days’ notice prior to any hearing or investigation.

The Court of Industrial Relations issued an order for the provisional reinstatement of Alforque pending the merits of the dismissal.
It was found that the dismissal failed to comply with the agreed procedure of giving notice and an opportunity for hearing, as stipulated in the settlement agreement.
A subsequent motion to reconsider the order was denied, leading to the present petition in the Supreme Court.

The petition alleged that the Court of Industrial Relations lacked jurisdiction because:

The petition was received after the enactment of Republic Act No. 875, despite being mailed beforehand.
The dispute involved only one employee (Alforque) rather than all 31 members of the labor union.
There was no labor dispute between the employer and the workers as required by law.

In response, the court clarified and reinforced established practices regarding mailing dates and the broad definition of a labor dispute.

Whether the petition should be deemed as filed before or after the enactment of Republic Act No. 875, given that it was mailed prior to June 17, 1953.
Whether the mailing date is validly considered the date of filing, thereby ensuring the court’s jurisdiction under the old standard.

Whether the dismissal of a single employee, whose employment terms included a mandatory hearing procedure, constitutes a “labor dispute” within the meaning of Republic Act No. 875.
Whether the dispute between the union and the employer over the enforcement of the settlement agreement qualifies as a controversy concerning terms, tenure, or conditions of employment.

Whether the settlement agreement, reached in 1950, remained applicable to future acts of dismissal despite arguments that it might have only terminated the dispute present at that time.
Whether the continued employment relationship between Caltex (Philippines) Inc. and its workers implies ongoing adherence to the agreed terms of the settlement.