G.R. No. 168406 - Club Filipino, Inc. vs. Bautista

Petitioner Club Filipino, Inc. is a non-stock, non-profit corporation duly formed and existing under Philippine laws.
Atty. Roberto F. de Leon serves as its president.
Respondents are former officers and members of the Club Filipino Employees Association (the union).

The company and the union had a CBA in force which expired on May 31, 2000.
During the post-expiration "freedom period," the union made several demands for the commencement of new negotiations.
The company replied that it could not muster a quorum, effectively stalling negotiations.

Sometime in 2000, the union submitted its formal CBA proposal to the company’s negotiating panel and repeatedly requested negotiations.
The company cited various reasons, including the illness of the management panel chairman, to avoid negotiation.
In an effort to compel the company to negotiate, union officers filed a request for preventive mediation with the National Conciliation and Mediation Board (NCMB), but the management did not engage at the negotiating table.

A meeting between the union and management took place on April 5, 2001, concluding with both parties declaring a deadlock in their negotiations.
On April 6, 2001, the union filed a notice of strike with the NCMB on the grounds of bargaining deadlock and failure to bargain.
The union’s notice did not include the company’s counter-proposal, as it had not been received at that time.

On April 22, 2001, the company formally responded to the union’s demands by submitting the first part of its economic counter-proposal.
The company subsequently submitted the second part of its counter-proposal on May 11, 2001.
Despite the company’s responses, the union maintained its improved proposal and the company refused to further improve its offer.

The union staged a strike on May 26, 2001, citing the deadlock in CBA bargaining.
On May 31, 2001, the company filed a petition before the National Labor Relations Commission (NLRC) to declare the strike illegal and sought the termination of the union officers who participated.
On November 28, 2001, a Labor Arbiter declared the strike “procedurally infirm and therefore illegal” due to the union’s failure to attach its written CBA proposal, the company’s counter-proposal, and proof of a request for a conference to settle the dispute.
As a result, all union officers were deemed terminated from service but were entitled to separation pay equivalent to that granted under the company’s retrenchment program.
The NLRC affirmed the Labor Arbiter’s decision on September 30, 2002, and respondents’ motion for reconsideration was denied.
Subsequently, aggrieved respondents elevated the matter to the Court of Appeals (CA) via a petition for certiorari.
On May 31, 2005, the CA set aside the NLRC and Labor Arbiter’s rulings with respect to certain union officers, ordering the payment of backwages, benefits, and computed separation pay, while dismissing the petition for others.
Petitioners then sought review from the Supreme Court on the issue of the legality of the strike staged by the union on May 26, 2001.

Whether the strike staged by the union on May 26, 2001, was legal or illegal.
Whether the union’s failure to attach the company’s counter-proposal to the notice of strike rendered the notice defective.

Whether the union could be faulted for not including documents (the company’s counter-proposal) that were not in its possession at the time of filing.
The interpretation of the phrase “as far as practicable” in Rule XXII, Section 4 of the Omnibus Rules Implementing the Labor Code.

Whether the automatic dismissal of union officers based on the alleged illegal strike was justified.
Whether there was sufficient evidence that the union officers knowingly participated in illegal strike activities, as required by law.