G.R. No. L-23689 - Carillo vs. Allied Workers Association of the Philippines

Allied Workers’ Association of the Philippines (AWA)
Rafael Didal
Baltazar de Asis
Diego Caballes
Crispin Buenafe
The Honorable Artemio C. Macalino, Executive Judge of the Court of Agrarian Relations

Originally, the respondents were employed at Hacienda Fara-on, Cadiz, Occidental Negros as farm workers and laborers.

Their duties included cutting cane points, weeding, clearing the field, hosing, and brushing the boundaries of the field.

Subsequently, at different times, the same individuals – along with an additional worker, Sebastian Rizalino – were appointed as security guards in the Hacienda.

The workers, already affiliated with the plaintiff Union (AWA), continued their work as security guards.

On May 21, 1963, defendant Mayo Lopez Carillo, co-owner and administrator of Hacienda Fara-on, summoned the security guards to his office.
He informed them that while he was aware of their union membership, it was not permissible for security guards to be affiliated with the union.
He presented them with a choice: either relinquish their union membership or be transferred to another department to perform farm work—a position associated with a lower wage rate.

The security guards, finding the alternative work demeaning and less remunerative, refused to report for work under the imposed conditions.
Their refusal was interpreted as a constructive discharge manifesting an act of unfair labor practice.

On September 22, 1964, Judge Artemio C. Macalino of the Court of Agrarian Relations rendered a decision ordering:

The reinstatement of respondents (the security guards) to their former positions at Hacienda Fara-on.
The payment of back wages computed at a daily rate of Two Pesos and Seventy-five Centavos (P2.75), calculated on a weekly basis beginning May 22, 1963 until their actual reinstatement.
Payment of costs against the petitioners.

The petitioners subsequently filed for review challenging the decision on multiple grounds, including:

A factual claim that the transfer amounted to a constructive discharge.
A legal contention regarding the applicability of the Industrial Peace Act and the Land Reform Code, noting that the acts in question occurred before the enactment of the latter.

Whether the Hacienda, by imposing the condition that security guards must relinquish their union membership or face a transfer to a lower-paying farm work position, committed an act of unfair labor practice.
Whether forcing the security guards into a different, less remunerative work assignment amounted to a constructive discharge.
Whether the findings on factual evidence, including the imposition of an employment condition to deter union membership and the subsequent refusal of the workers to report for work, justify the reinstatement order along with the awarding of back wages.
Whether the contention regarding the applicability of the Industrial Peace Act and the Land Reform Code is valid given the timing of their enactment relative to the incidents complained of.