G.R. No. L-48687 - Genconsu Free Workers Union vs. Inciong

Petitioners include Genconsu Free Workers Union, Benjamin Cuevas, and Carlos Enriquez, who were employees of Allenco Steel Corporation.
The dispute arose after the National Labor Relations Commission (NLRC) ordered the reinstatement of petitioners Cuevas and Enriquez based on their claims of unjust dismissal and unfair labor practices.
Despite the reinstatement order, respondent Deputy Minister of Labor, Amado G. Inciong, failed to grant backwages to the petitioners, leading to the present certiorari proceeding.

Benjamin Cuevas was advised of his transfer to the Scrap Yard Section and was given a one-week period to indicate whether he accepted the new job.
Cuevas’ failure to report within the given time resulted in the filing of a clearance application for termination based on alleged abandonment.
The NLRC observed that while Cuevas did not report on time, he subsequently opposed the clearance and sought reinstatement, suggesting that he did not truly abandon his job.
The commission found that the one-week period was possibly too short for Cuevas, especially since the offered position was novel to him, thereby raising questions about the fairness of the time allowed.

Enriquez was on sick leave at the time when respondent Allenco Steel Corporation issued recall letters to the laid-off workers.
Since Enriquez was not dismissed and even had his sickness benefit claim endorsed by management, the NLRC concluded there was no basis for awarding backwages in his case.

The NLRC and respondent Deputy Minister of Labor found that there were no discriminatory acts or unfair labor practices committed by the private respondent Allenco Steel Corporation with respect to the petitioners.
The NLRC’s decision, together with the terse order of affirmance by the Deputy Minister, contained ambiguities—particularly in the factual determination on Cuevas’ failure to report for work.
The ambiguity centered on whether the denial of backwages to Cuevas was justified given that he was arguably not given adequate time to deliberate on accepting the new job.

The petition asserted that the decision resulting in the loss of backwages, especially for Cuevas, was unfair and possibly violated substantive due process due to its lack of clarity and precision.
The Court expressed concern that the current factual determination did not provide a full understanding of the circumstances surrounding Cuevas’ failure to report for work.
Due to this ambiguity, equity and fairness necessitated a remand to the NLRC for further clarification, particularly regarding the duration of the delay and the justification for such non-reporting.

Whether the failure to grant backwages to petitioners, particularly Benjamin Cuevas, due to insufficient time allowed to consider the acceptance of a new job, constitutes a violation of substantive due process.

The issue involves examining if the administrative actions by both the NLRC and the Deputy Minister of Labor amounted to "sheer oppression" by denying the petitioners a fair opportunity to defend their rights.
Whether the ambiguous findings, especially regarding the precise circumstances of Cuevas’ non-reporting, warrant a remand for a more detailed inquiry.

Whether the NLRC’s findings that there were no discriminatory acts or unfair labor practices committed by Allenco Steel Corporation can be accepted without further inquiry in light of the petitioners’ claims.

Whether the decision to grant reinstatement without backwages, particularly in the case of Cuevas, should be modified to address the potential unfairness arising from the vague facts on record.