Title
Gold City Integrated Port Service, Inc. vs. National Labor Relations Commission
Case
G.R. No. 103560
Decision Date
Jul 6, 1995
INPORT employees staged an illegal strike in 1985; SC ruled union members entitled to separation pay but no backwages, while union officers received no relief.

Case Digest (G.R. No. 103560)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case:
    • Gold City Integrated Port Service, Inc. (INPORT) filed a petition for certiorari against the National Labor Relations Commission (NLRC) regarding its decision in a labor dispute involving 27 private respondents. The case was consolidated with another petition (G.R. No. 103599) where the employees were the petitioners and INPORT was the respondent.
  • The Strike:
    • On April 30, 1985, INPORT employees, members of the Macajalar Labor Union - Federation of Free Workers (MLU-FFW), staged a strike to protest wages, thirteenth-month pay, and hazard pay. The strike paralyzed operations at the port of Cagayan de Oro.
    • The strikers filed individual notices of strike, but the strike was declared illegal by the Labor Arbiter for failing to comply with the formal requirements under Article 264 of the Labor Code.
  • Return to Work:
    • After a temporary restraining order was issued on May 7, 1985, most strikers returned to work, but 31 employees (private respondents) continued the strike. INPORT required these remaining strikers to undergo a screening process before returning to work.
  • Labor Arbiter’s Decision:
    • The Labor Arbiter ruled the strike illegal but held that the workers did not lose their employment status since there was no evidence of illegal acts during the strike. The private respondents were ordered to be reinstated without screening, except for six union officers who were required to seek reconsideration from INPORT.
  • NLRC’s Decision:
    • The NLRC modified the Labor Arbiter’s decision, awarding separation pay in lieu of reinstatement and backwages. On reconsideration, the NLRC reduced the separation pay to six months and deleted the backwages, awarding P1,000.00 as compensation instead.
  • Petitions to the Supreme Court:
    • INPORT challenged the NLRC’s award of separation pay and backwages, arguing that the strike was illegal. The private respondents, on the other hand, contested the reduction of separation pay and deletion of backwages.

Issues:

  • Whether the strike staged by INPORT’s employees was illegal.
  • Whether the private respondents are entitled to separation pay and backwages despite the illegal strike.
  • Whether the NLRC committed grave abuse of discretion in modifying its original decision.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court granted INPORT’s petition in G.R. No. 103560, awarding one month’s salary for each year of service until 1985 as separation pay to the private respondents who were not union officers. The petition in G.R. No. 103599 was dismissed for lack of merit. The Court upheld the NLRC’s decision but modified the reliefs awarded to align with the law and the circumstances of the case.

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