Facts:

The case involves the Federation of Free Workers (FFW) and several of its union officers, including Gerardo Rosana, Fe Divina, and others, as petitioners against Hon. Amado G. Inciong and Aris (Philippines), Inc. as respondents. The events leading to this case began on September 17, 1977, when a certification election was held at Aris (Philippines), Inc., a domestic corporation engaged in manufacturing leather gloves for export. The FFW was declared the authorized bargaining representative after garnering the highest number of votes. Subsequently, a memorandum of agreement was executed on February 3, 1978, recognizing FFW as the bargaining representative and allowing it to administer the existing collective bargaining agreement (CBA) until a new one was negotiated. The CBA included a "no strike - no lockout" clause.

Negotiations for a new CBA began but reached a deadlock by February 28, 1978, prompting FFW to file a notice of strike. Despite attempts at conciliati...

Facts:

1. Parties Involved:

   • Petitioners: Federation of Free Workers (FFW), a legitimate labor organization, and its union officers and members.
   • Respondents: Hon. Amado G. Inciong, Deputy Minister of Labor and Employment, and Aris (Philippines), Inc., a domestic corporation engaged in manufacturing leather gloves for export.

2. Certification Election and CBA Negotiations:

   • On September 17, 1977, a certification election was held, and FFW was declared the authorized bargaining representative.
   • On February 3, 1978, a memorandum of agreement was executed between FFW and Aris (Philippines), Inc., recognizing FFW as the bargaining representative and agreeing to negotiate a new collective bargaining agreement (CBA).

3. Strike Declaration and Deadlock:

   • Negotiations for a new CBA failed, leading to a deadlock.
   • On February 28, 1978, FFW filed a notice of strike. Conciliation meetings were held but failed to resolve the dispute.
   • On April 1, 1978, FFW staged a strike across all three plants of Aris (Philippines), Inc.

4. Assumption of Jurisdiction by the Labor Minister:

   • The Deputy Minister of Labor assumed jurisdiction over the dispute, as Aris (Philippines), Inc. was classified as a vital industry protected by Presidential Decree No. 823.
   • On April 2, 1978, an order was issued directing a wage increase and ordering strikers to return to work. However, the strikers intensified their picketing instead.

5. Illegal Strike Declaration and Termination of Union Officers:

   • On April 11, 1978, the Deputy Minister declared the strike illegal, ordered non-officer strikers to return to work, and granted clearance to terminate the union officers.
   • On January 29, 1979, the Deputy Minister granted clearance to terminate the services of 18 union officers and members.

6. Petition to the Supreme Court:

   • Petitioners filed a petition for certiorari, challenging the decisions of the Deputy Minister.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Finality of the April 2, 1978 Order:

   • The April 2, 1978 order did not attain finality because the petitioners failed to comply with its terms, particularly the directive to lift the strike and return to work.

2. Authority of the Deputy Minister:

   • The Deputy Minister had the authority to revoke or modify his earlier order, as the April 2, 1978 order was not final and executory.

3. Illegality of the Strike:

   • The strike was illegal because:
     a. Aris (Philippines), Inc. was a vital industry protected by Presidential Decree No. 823.
     b. The Secretary of Labor had assumed jurisdiction over the dispute, prohibiting strikes.
     c. The union engaged in coercive and illegal strike activities, such as blockading plant entrances.

4. Loss of Employment Status:

   • Union officers and members who participated in the illegal strike lost their employment status, as their actions violated labor laws.

5. Remedy of Appeal:

   • Petitioners failed to appeal the April 11, 1978 decision to the Office of the President, allowing it to lapse into finality. Certiorari cannot substitute for a lost appeal.