Title
Supreme Court
Fadriquelan vs. Monterey Foods Corp.
Case
G.R. No. 178409
Decision Date
Jun 8, 2011
A labor dispute arose after a CBA expired, leading to strikes and union officer terminations. The Supreme Court ruled some terminations illegal, distinguishing between officers and workers, and ordered compensation for wrongful dismissals.

Case Digest (G.R. No. 148862)
Expanded Legal Reasoning Model

Facts:

  • Background of the Dispute
    • The three-year collective bargaining agreement (CBA) between the union (Bukluran ng Manggagawa sa Monterey-Ilaw at Buklod ng Manggagawa) and Monterey Foods Corporation expired on April 30, 2002.
    • Negotiations for a new CBA reached a deadlock leading the union to file a notice of strike with the National Conciliation and Mediation Board (NCMB) on March 28, 2003.
  • Intervention by the Company and DOLE
    • To preempt the strike, the company filed a petition for the assumption of jurisdiction over the dispute with the Department of Labor and Employment (DOLE) on April 30, 2003.
    • The DOLE Secretary assumed jurisdiction over the dispute on May 12, 2003, enjoining the union from holding any strike and directing both parties to desist from actions that could aggravate the situation.
  • Actions Taken by the Union and Subsequent Developments
    • Despite the assumption order, the union filed a second notice of strike on May 21, 2003, alleging unfair labor practices by the company.
    • On June 10, 2003, the company charged union officers with committing acts of slowdown.
    • On June 16, 2003, new notices were sent to union officers informing them of their termination for defying the DOLE Secretary’s assumption order.
    • The union later filed a third notice of strike on June 23, 2003, alleging union busting and illegal dismissal of union officers.
    • On July 7, 2003, the company petitioned the National Labor Relations Commission (NLRC) for compulsory arbitration, though the motion was denied by the DOLE Secretary who subsumed the third notice of strike under the previous ones.
  • DOLE and Court Decisions
    • The DOLE, on November 20, 2003, upheld the company’s termination of 17 union officers.
    • The union and its officers appealed the decision to the Court of Appeals (CA).
    • On May 29, 2006, the CA upheld the termination of 10 union officers while declaring the dismissal of the other 7 as illegal.
    • Both parties subsequently sought recourse to the Supreme Court in separate petitions.

Issues:

  • Whether the Court of Appeals erred in holding that slowdowns actually transpired at the company’s farms.
    • Examination of the evidence indicating that union officers and workers conducted a slowdown on May 26, 2003.
    • Evaluation of the union’s claim that the gatherings were merely assemblies and not protest demonstrations.
  • Whether the Court of Appeals erred in holding that union officers committed illegal acts warranting their dismissal.
    • Consideration of the distinction between the liability of ordinary workers and that of union officers in participating in illegal slowdown strikes.
    • Assessment of the proper identification and evidence linking union officers to the slowdown activity.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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