G.R. No. L-36545 - Esso Phil., Inc. vs. Malayang Manggagawa sa Esso

The case involves the petition of Esso Philippines, Inc. (now PetroPhil Corporation) for review of the en banc resolution of the defunct Court of Industrial Relations dated February 5, 1973.
The petition challenges the trial court’s order of September 4, 1972, which dismissed the execution petition of private respondents (Malayang Manggagawa sa Esso [MME] and the Philippine Federation of Petroleum Workers [PFPW]) that sought to implement the Supreme Court’s decision rendered on February 27, 1971.
The disputed execution order was to implement portions of an earlier judgment from April 27, 1966, which had granted several remedial measures in labor disputes between Esso and the striking union.

The core issues involve the conditions under which certain positions—specifically, assistant truck drivers (or truck helpers) and fillers—were abolished, and the rightful entitlement of workers to reinstatement or backwages.
Additional disputed relief includes:

Restoration of transportation and meal allowances for employees assigned to units at the Manila International Airport (MIA) and JOCASP.
Payment of backwages to compulsorily prematurely retired employees from the date of their premature retirement until the contractual retirement age of 60, together with retirement benefits under the collective bargaining agreement (CBA) of April 8, 1963.
The validity and continuing effect of certain collective bargaining agreements, notably the April 8, 1963 CBA and subsequent agreements of May 31, 1968 and June 30, 1971.

Central to the dispute is a strike by the petitioner MME on February 19, 1965, with additional complications arising from an earlier strike on October 4, 1963.
Most of the MME members were originally members of the Citizens Labor Union (CLU), which is relevant to issues of liability for illegal strike actions as determined in related cases (e.g., ULP-3934).
The trial court and earlier industrial court decisions had bifurcated the issues, reserving some demands for determination in separate cases pending before the industrial court.

The decision under review is not an isolated ruling; it is interlinked with pending cases (notably ULP-3934 and ULP-3903) where:

In ULP-3934, a decision declared that the CLU members who actively participated in the illegal strike lost their status as employees.
In ULP-3903, the employer (and rival union) dispute is also connected with the composition and rights of the workers, influencing the execution of the Supreme Court’s decision.

The resultant procedural fragmentation led to part of the relief being executed while other issues on the enforceability of newer agreements and individual employee status awaited resolution.

The Supreme Court, while affirming parts of the trial court’s decision, modified certain relief:

It reaffirmed the reinstatement of the abolished positions and the restoration of the withdrawn benefits, subject to set qualifications.
It modified the award regarding advanced (compulsorily premature) retirement so that backwages should be paid from the date of premature retirement up to the contractual retirement age.

The final execution was made contingent upon further determinations by the National Labor Relations Commission (as successor to the respondent court) on unresolved issues such as:

The effect of the validity or invalidity of subsequent CBAs on the automatic renewal of the April 8, 1963 agreement.
Determination of which employees, particularly those formerly of the CLU but not already separated by the ULP-3934 decision, are entitled to reintegration or backwages.

Whether the execution of the Supreme Court’s decision of February 27, 1971 should be carried out in light of the fragmented and pending issues in related cases before other branches of the industrial court.
Whether the partial execution—restoring some relief while leaving other matters pending—is constitutionally and procedurally acceptable.

Whether the positions of assistant truck drivers (or truck helpers) and fillers, which were abolished under earlier agreements, should be restored.
Whether those employees not specifically terminated through ULP-3934 should be reinstated and entitled to backwages from their separation up to the relevant cutoff date (July 8, 1966).

Whether employees assigned to MIA and JOCASP should have their transportation and meal allowances restored from the time such benefits were withdrawn.
How the payment of additional backwages and eventual determinations regarding benefits under the CBA (April 8, 1963) interact with subsequent agreements.

How the determination of liability for the illegal strike (specifically, participation versus mere union membership) affects the entitlement to reinstatement or benefits.
Whether the principle of vicarious liability (already discarded in prior rulings) precludes benefits for those who did not actively participate in the illegal strike.

Whether the April 8, 1963 CBA retains its enforceability in the face of purportedly superseding agreements (May 31, 1968 and June 30, 1971).
The effect of any invalidity of the new agreements on the rights of the workers to have their positions restored.