G.R. No. L-2548 - Dee C. Chuan and Sons, Inc. vs. Court of Industrial Relations

The petitioner appealed a decision of the Court of Industrial Relations which ordered:

An increase of P0.030 per day to all its employees and laborers, except those under the "pakiao system".
Granting 15 days of vacation leave with full pay and 15 days of sick leave with full pay annually to its laborers, under certain conditions.

Reduction of salaries and wages of its employees and laborers, including those of work-contract laborers employed by Julian Lumanog.
Damages resulting from a laborers’ strike.
Filing a bond by Julian Lumanog under Act No. 3959 and reducing the wages of his work-contract laborers.

A strike had been declared by the petitioner’s laborers on April 12, 1947.
The petitioner argued that the strike was illegal or unjustified because it allegedly:

Originated from unfounded demands.
Was planned by the Congress of Labor Organizations to provoke a general strike and embarrass the Roxas Administration.

There was a previous industrial dispute between the petitioner and its laborers which culminated in a final judgment issued by the Court of Industrial Relations on November 23, 1946.

The petitioner contended that the earlier award, pursuant to Section 17 of Commonwealth Act No. 103, was effective for three years, thereby implying that a strike should not occur during this statutory period.
Although petitioner's argument acknowledged that Section 17 did not expressly prohibit strikes during the award's effectiveness, it inferred a legislative intent aimed at forestalling strikes.
The Court of Industrial Relations maintained that a strike does not automatically conflict with or destroy the efficacy of an award or decision, as it may still be enforced or reopened by the court when necessary.

The petitioner's financial ability, as shown by the evidence, justified the wage increase and the granting of vacation and sick leaves.
The ruling was also supported by prior decisions, notably in Leyte Land Transportation Company, Inc. vs. Leyte Farmer's and Laborers' Union, which underscored that granting leaves with pay aids in maintaining worker efficiency and long-term productivity.
The petitioner's claims concerning damages and wage reduction were dismissed, partly because the strike was found to be legal and justified, and because the laborers of Julian Lumanog were determined to be independent contractors, thus placing them outside the petitioner’s direct employment relationship.

Whether the strike declared on April 12, 1947, is illegal or unjustified given its alleged origin from unfounded demands and organized manipulation by labor organizations.
Whether the existence of a binding award from a previous industrial dispute should inherently prohibit or nullify the declaration of a strike during its statutory three-year effectiveness.

Whether the decisions regarding wage increases, vacation leaves, and sick leaves—based on the petitioner’s financial condition—were within the judicial mandate of the Court of Industrial Relations.
Whether the Court had jurisdiction over the claims the petitioner sought against Julian Lumanog and his work-contract laborers, particularly given their classification as independent contractors.

Whether a legal and justified strike can preclude the employer from recovering damages for any resultant labor stoppage.
The impact of the strike on determining whether the laborers had effectively ceased or maintained their employment relationship with the petitioner.