Case Digest (G.R. No. 90634-35)
Facts:
Carmelcraft Corporation &/or Carmen V. Yulo v. National Labor Relations Commission, Carmelcraft Employees Union, Progressive Federation of Labor, represented by its local president George Obana, G.R. Nos. 90634-35, June 06, 1990, Supreme Court First Division, Cruz, J., writing for the Court.
The petitioners are Carmelcraft Corporation and its president and general manager, Carmen V. Yulo; the respondents are the National Labor Relations Commission (NLRC), the Carmelcraft Employees Union and the Progressive Federation of Labor (represented by its local president George Obana). After the union was registered, it sought recognition from Carmelcraft but was refused, and in June 1987 filed a petition for a certification election.
On July 13, 1987, Carmen Yulo announced in a meeting with employees that the company would cease operations on August 13, 1987, allegedly because of serious financial losses; operations did in fact cease on that date. On August 17, 1987, the union filed a complaint with the Department of Labor charging illegal lockout, unfair labor practice and damages, and on August 18, 1987 filed a separate complaint for unpaid wages, emergency cost-of-living allowances, holiday pay and other benefits.
On November 29, 1988, the Labor Arbiter declared the shutdown illegal and violative of the employees’ right to self-organization and granted claims for unpaid benefits. On appeal the NLRC modified the Arbiter’s decision by ordering, among other things, payment for underpaid wages and benefits for a three-year period and separation pay equivalent to one-half month pay for every year of service (fractions of six months or more counted as one year); otherwise it affirmed the Arbiter. The NLRC found no grave abuse of discretion in the Arbiter’s findings and credited the union’s version that the shutdown was motivated by the establishment of the union rather than by bona fi...(Subscriber-Only)
Issues:
- Did the petitioners commit an unfair labor practice/illegal lockout by closing operations to frustrate the employees’ union and thus become liable for the remedies ordered by the NLRC?
- Are the employees estopped by quitclaims or satisfaction receipts from claiming unpaid wages and other benefits?
- Is Carmen V. Yulo personally liable for the acts of ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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