G.R. No. L-15594 - Cano vs. Court of Industrial Relations

The case involves a complaint for unfair labor practice filed by the Acting Prosecutor of the Court of Industrial Relations.

The complaint arose from the allegation that respondents—Emilio Cano, Ariston Cano, and Rodolfo Cano (holding the positions of president and proprietor, field supervisor, and manager, respectively, of Emilio Cano Enterprises)—dismissed certain employees for refusing to disaffiliate from or dissolve their labor union and for engaging in union activities.

Complainants included the Emilio Cano Employees and Workers Union (PTUC), along with individual employees Cayetano Olba, Salvador Labastida, Honorata Cruz, and Albino Tanghal.

After filing, the respondents moved to dismiss the complaint by denying the acts imputed to them and alleging that the separations were for reasons other than union affiliation or activities.

On December 11, 1956, after partial testimony had been taken, complainants Cayetano Olba and Albino Tanghal moved to be dropped from the complaint; however, that motion was never acted upon by the court.

Evidence continued to be taken even as some complainants sought withdrawal from the proceedings.

On July 3, 1957, acting on a motion filed by the complainant union’s president, the court ordered the dismissal of the entire case.

On July 9, 1957, Atty. Carlos E. Santiago, representing complainants Honorata Cruz and Salvador Labastida, filed a motion for reconsideration of the dismissal order, contending that the union president was not duly authorized to withdraw their individual complaints.

On August 21, 1957, the court en banc resolved to reinstate the case for further evidentiary hearing regarding the motion for reconsideration, remanding it to the judge a quo to substantiate the allegations.

On March 10, 1958, after the receipt and review of supporting evidence for the motion, the judge a quo set aside the dismissal order as far as it affected Honorata Cruz, while dismissing the case concerning Salvador Labastida, who had requested dismissal separately.

The judge a quo subsequently continued to receive evidence, including that implicating respondents in acts of intimidation, and later rendered a decision on January 7, 1959, finding that the dismissal of Honorata Cruz was unjustly executed and amounted to an interference in her union activities.

The final judgment ordered the reinstatement of Honorata Cruz with back wages from the date of separation to actual reinstatement, while respondent Ariston Cano was exonerated for lack of evidence.

Petitioner Rodolfo Cano, appealing from the decisions of both the trial court and the court en banc, raised various issues regarding the procedural conduct and evidentiary handling, including the participation of the court prosecutor and substitution of parties after a respondent’s death.

Whether the court en banc erred in entertaining the motion for reconsideration filed by counsel for complainants Cruz and Labastida without the aid or supervision of the court prosecutor.
Whether the trial judge erred in setting aside the dismissal order, receiving evidence, and ordering the reinstatement of the case as far as complainant Honorata Cruz was concerned.
Whether the trial judge erred in rendering judgment against deceased respondent Emilio Cano without ordering the proper substitution of parties.
Whether evidence not directly connected to the reinstated case (pertaining to the dismissed portions regarding the other complainants) should have been stricken from the record, thereby affecting the findings in favor of Honorata Cruz.
Whether the court en banc erred in denying the petitioner's motion for reconsideration regarding the procedural and evidentiary concerns raised.