G.R. No. 195163 - Ergonomic Systems Philippines, Inc. vs. Enaje

Respondents were union officers and members of the Ergonomic System Employees Union-Workers Alliance Trade Unions (local union).
Petitioners are Ergonomic Systems Philippines, Inc. (ESPI) along with its representatives Phillip C. Ng and Ma. Lourminda O. Ng.
The dispute arose out of issues relating to an existing Collective Bargaining Agreement (CBA) and subsequent labor controversies.

On October 29, 1999, the local union entered into a CBA with ESPI effective for five years, or until October 2004.
Initially, the local union was affiliated with the Workers Alliance Trade Unions-Trade Union Congress of the Philippines (Federation) but was not independently registered.
On November 15, 2001, prior to the expiration of the CBA, the union officers secured independent registration of the local union with the DOLE Regional Office.

Union officers were charged by the Federation for attending and participating in other union seminars and activities using union leaves without consent, as well as for conspiring in the disaffiliation from the Federation.
On January 10, 2002, the Federation rendered a decision finding the union officers guilty of disloyalty, resulting in their immediate expulsion from the Federation.
On January 11, 2002, the expelled officers’ status was communicated to ESPI along with a recommendation for their termination as provided by the CBA (Sections 2 and 3, Article 2).

ESPI notified the union officers about the Federation’s demand and gave them 48 hours to explain; most officers refused to receive the notice.
On February 20, 2002, ESPI issued letters of termination, which were again refused by the officers.
The local union, in response, filed a notice of strike with the NCMB on February 26, 2002.
Various strike-related activities ensued from February 21 to March 2, 2002:

A series of noise barrage and “slow down” activities were staged by the local union.
Specific groups of union members refused to submit their Daily Production Reports (DPRs), abandoned work, or did not report for work without leave.

On January 27, 2003, respondents filed a complaint for illegal dismissal and unfair labor practice against ESPI and its representatives.
The Labor Arbiter (LA) ruled on January 31, 2005, holding that the disaffiliation from the Federation did not amount to disloyalty to the local union and that the dismissal was unwarranted though ESPI’s actions were in response to the Federation’s demand.
The NLRC, in its decision on October 31, 2007, affirmed the LA’s ruling by emphasizing that the dismissal was predicated solely on the Federation’s request.
The Court of Appeals (CA) modified the NLRC ruling on September 21, 2010, affirming the reversion to the status quo ante but deleting the separation pay provision, based on the analysis that the strike was illegal.
The petition for review on certiorari was eventually brought before the Supreme Court, leading to the final rendition of the case.

Whether the Federation may invoke the union security clause in the CBA to demand the dismissal of union officers and members.

The petitioners contend that the union officers and members were liable for disloyalty and other union-related infractions.
The respondents maintain that they merely disaffiliated from the Federation without constituting disloyalty to the local union.

Whether the strike conducted by the union members complied with the legal requirements.

Issues include the failure to take a valid strike vote and to submit the results of the voting to the NCMB within the required period.
Petitioners argue that these lapses render the strike illegal and justify dismissal, whereas respondents counter that any illegal acts require proof beyond mere participation.

The petitioners argue that the dismissals were proper and based on multiple grounds including violation of the union security clause, non-compliance with strike procedures, and abandonment of work.
The respondents assert that their dismissal was unjustified since the grounds for termination were either non-existent or improperly attributed, especially given the separate personalities of the local union and the Federation.

The legal debate also questioned the appropriate relief – whether respondents are entitled to reinstatement, back wages, or separation pay.