Case Digest (G.R. No. L-18334)
Facts:
Filemon Dionela, Anacleto Candelaria, Angel Balicao Ramon Cartojano, Euseo Terante, Amado Macato, Mariano Madrona, Jose Valencia, Felix Trinidad, Pedro Tugon, Eleuterio Rioja, Julio Lumontad, Pedro Bakaril, Cresencio Corte, Jose Bacaoco, Romeo De Jesus, Anastacio Aviles, Pilar Quevedo, Esperanza Relos, Marciano Magalong, Jesus Refareal, Angel Lebrun, Monico Lucas, and Demetrio Balauro v. The Court of Industrial Relations, E. R. Squibb and Sons (Phil.) and Carleton Ashley, G.R. No. L-18334, August 31, 1963, the Supreme Court En Banc, Concepcion, J., writing for the Court.The case arose from labor controversies between E. R. Squibb and Sons (Phil.) (the corporation) and the Gas and Chemical Free Workers (the Union) and certain union members. On February 2, 1955 the Union and three of its members (Mariano Argamusa, Bienvenido Jose and Benigno Sabas) filed Case No. 598-ULP in the Court of Industrial Relations (CIR), charging the corporation and its general manager, Carleton Ashley, with unfair labor practices (ULP) for interfering with union activities and discriminating against those employees; a prosecutor later filed and supplemented the complaint seeking reinstatement with back pay.
While Case No. 598-ULP was pending, the Union declared a strike on March 22, 1955. The corporation sought and obtained injunctive relief (Case No. 6-Inj.): the CIR issued a temporary restraining order on April 2, 1955 that was made permanent on December 21, 1955 after findings of violence and intimidation on the picket line. Subsequently the Union and the corporation negotiated an "amicable settlement" that, among other terms, provided that the corporation would pay each striking Squibb employee an amount equivalent to three months' separation pay.
Dissatisfied with that settlement, on December 28, 1955 Filomeno Dionela (vice-president of the Union) and 27 employees filed in Case No. 598-ULP a motion to disauthorize Union counsel to represent them. Thereafter the Union president, the three originally named employees, and their counsel executed a motion to withdraw the complaints (filed January 17, 1956) with the Acting Prosecutor's concurrence; the CIR dismissed the complaints by order dated February 13, 1956. Dionela et al. sought reconsideration but failed to prosecute their motion and it was dismissed.
On February 17, 1956 Dionela and 23 co-movants instituted a new ULP charge (Case No. 895-ULP) against the corporation and Ashley; an Acting Prosecutor filed the corresponding complaint on May 9, 1956 and it was later amended. The complaint alleged that petitioners had been discriminated against and refused reinstatement after the dismissal of Case No. 598-ULP, constituting ULP. A suppletory complaint (filed February 7, 1957) added allegations that respondents had inquired into union membership, coerced employees to resign, used strikebreakers, and had dismissed Monico Lucas and Demetrio Balauro for union activities.
The CIR rendered the decision now appealed from: it dismissed the petitioners' ULP claims but ordered the corporation to pay the agreed three months' separation pay to claimants who...(Pro-only)
Issues:
- Is the compromise agreement settling Case No. 598-ULP binding upon petitioners who dissented from the Union's approval of that settlement?
- Were the subsequent complaints and the additional allegations in the suppletory complaint (Case No. 895-ULP) actionable apart from the prior settlement, or were they barred because they arose during the same...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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