Title
De Paul/King Philip Customs Tailor vs. National Labor Relations Commission
Case
G.R. No. 129824
Decision Date
Mar 10, 1999
Employees of De Paul/King Philip Customs Tailor formed a union in 1993, alleging unfair labor practices and illegal dismissal. The NLRC ruled in their favor, ordering reinstatement and back wages, upheld by the Supreme Court.
illegal dismissal
backwages
grave abuse of discretion
A

Case Digest (G.R. No. 216021)

Facts:

  • Parties and employment relationship
  • Petitioners De Paul/King Philip Customs Tailor (and/or its proprietors Milagros Chuakay and William Go) were the employer of the private respondents.
  • Private respondents were employees of De Paul/King Philip Customs Tailor.
  • All private respondents formed a labor organization and later filed charges against petitioners with the NLRC.
  • Formation of the labor organization and related union activities
  • Private respondents formed a labor organization on fourteen February 1993.
  • They affiliated with the Federation of Free Workers on twenty-six February 1993.
  • Their union was called FFW-Kapatirang Manggagawa sa De Paul/King Philip Customs Tailor.
  • A charter was issued by the FFW in favor of the union and it was registered with the Bureau of Labor Relations.
  • On ten March 1993, the union filed a certification election with DOLE-NCR.
  • On twenty-three March 1993, the union filed a notice of strike due to the dismissal of its union officers and an alleged unfair labor practice.
  • On six April 1993, union president Victoriano Santos stopped working.
  • Other private respondents followed with a “walk out” on twelve April 1993.
  • NLRC case initiation and certification election outcome
  • On thirteen May 1993, the union filed against the petitioners a case for unfair labor practice, illegal dismissal, and non-payment of overtime pay before the NLRC National Capital Region Arbitration Branch (NLRC Case No. 00-05-03323-93).
  • On twenty-six May 1993, the petition for certification election was dismissed on the ground that the union could not be the bargaining agent for two companies.
  • The certification election dismissal was not appealed.
  • Disaffiliation from FFW and amended complaint
  • On twenty-one June 1993, private respondents disaffiliated from the FFW.
  • The disaffiliation was attributed to the failure of the FFW to send a representative in two hearings of the private respondents’ case before the labor arbiter.
  • On twenty-eight June 1993, private respondents filed an amended complaint where they pursued the case in their individual capacities.
  • Rogelio Bartolay joined as a party-complainant.
  • The amended complaint listed private respondents’ dates of hiring, termination, and salary, including:
    • Victoriano Santos (hired May 16, 1980; terminated April 6, 1993; P5,200/mo.)
    • Bartolome Rebamutan (hired August 1987; terminated April 12, 1993; 6,000/mo.)
    • Marina Velasco (hired October 1977; terminated April 12, 1993; 4,000/mo.)
    • Vicitacion Solis (hired October 1979; terminated April 12, 1993; 300/day)
    • Rosalinda Habolin (hired April 1977; terminated April 6, 1993; 135/day)
    • Rosalin Abelida (hired November 1990; terminated April 10, 1993; 118/day)
    • Teresita Daclan (hired November 1985; terminated April 6, 1993; 120/day)
    • Belen Alvarez (hired September 1989; terminated April 12, 1993; 248/day)
    • Rogelio Bartolay (hired July 1987; terminated April 12, 1993; 4,200/mo.)
    • Rita Lucero (hired July 1990; terminated April 12, 1993; 172/day)
    • Geminiano Maderazo (hired February 1984; terminated April 12, 1993; 300/day)
    • Adolfo Mulato (hired May 1986; terminated April 12, 1993; 400/day)
    • Amparo Egos (hired February 1983; terminated April 12, 1993; 225/day)
    • Gloria J. Cruz (hired March 1992; terminated April 12, 1993; 248/day)
    • Flora Navea (hired April 1980; terminated April 12, 1993; 80/day)
    • Gabriel Fernando (hired February 1991; terminated April 12, 1993; 400/day)
    • Priscila Villavecer (hired April 1987; terminated April 12, 1993; 3,500/mo.)
    • Renato Villavecer (hired September 1977; terminated April 12, 1993; 4,000/day)
  • Parties’ respective positions before the labor arbiter
  • Private respondents’ position paper (filed twelve July 1993, before Labor Arbiter Arthur L. Amansec)
    • Private respondents alleged they were warned by petitioners not to organize any labor group or be a member of any existing labor organization.
    • They alleged they were threatened with dismissal if they did so.
    • Despite this, they organized the Kapatirang Manggagawa sa De Paul/King Philip Customs Tailor and affiliated with the FFW.
    • They claimed this allegedly triggered their termination.
  • Petitioners’ position paper
    • Petitioners asserted private respondents were not serious in organizing a union.
    • Petitioners claimed the union was merely a ploy to exact money from them.
    • Petitioners alleged this led to private respondents’ disaffiliation from the FFW.
    • Petitioners denied the alleged dismissal.
    • Petitioners asserted private respondents “walked out” preparatory to a planned strike.
    • Petitioners claimed most employees did not join the “walk out,” and that private respondents never returned.
    • Petitioners alleged notices were sent to private respondents to return to work.
    • Petitioners asserted willingness to accept some private respondents except those who allegedly made threatening phone calls.
    • Petitioners alleged the private respondents had already obtained employment in other tailoring shops.
  • Private respondent Santos’ supplemental affidavit
    • Santos denied that they were notified to return to work.
    • He alleged they were prevented from entering the work premises.
    • He alleged they were informed about their dismissal.
    • He alleged they returned in the succee...(Subscriber-Only)

Issues:

  • Whether the NLRC committed grave abuse of discretion (amounting to lack or excess of jurisdiction) in reversing the labor arbiter’s factual findings and in finding illegal dismissal
  • Whether the NLRC properly disregarded the labor arbiter’s finding based on the alleged absence of letters of dismissal.
  • Whether the NLRC’s conclusion of illegal dismissal had substantial support from the record.
  • Whether the NLRC acted in excess of jurisdiction when it treated petitioners’ return-to-work notices as mere fabrications
  • Whether the NLRC erroneously refused to consider the return-to-w...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)
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