Case Digest (G.R. No. 156635) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 156635 decided on January 11, 2016 under the 1987 Constitution, the Supreme Court resolved a labor dispute between The Hongkong & Shanghai Banking Corporation Employees Union (the Union) and its rank-and-file members as petitioners, and the National Labor Relations Commission (NLRC) and The Hongkong & Shanghai Banking Corporation, Ltd. (HSBC) as respondents. The parties’ relationship was governed by a collective bargaining agreement effective April 1, 1990 to March 31, 1993 (economic terms) and to March 31, 1995 (representational terms). When HSBC unilaterally implemented a Job Evaluation Program on January 18, 1993, the Union charged it with unfair labor practice (ULP), picketed intermittently for 11 months, and filed administrative proceedings. After a strike vote on December 19, 1993, a majority walked out on December 22 and allegedly blocked ingress and egress at HSBC’s Makati and Pasig offices, prompting HSBC to seek habeas corpus and injunctive relief. On Decem Case Digest (G.R. No. 156635) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Collective Bargaining
- The Hongkong & Shanghai Banking Corporation Employees Union (Union) was the certified bargaining agent of HSBC rank-and-file employees under a CBA effective April 1, 1990–March 31, 1993 (economic) and until 1995 (representational).
- On January 18, 1993, HSBC implemented a Job Evaluation Program (JEP) retroactive to January 1, 1993, altering salary scales per grade level.
- Dispute, Concerted Actions, and Strike
- The Union claimed the JEP was an unfair labor practice (ULP), demanded its suspension (Jan 20, 1993), and engaged in picketing from January 22, 1993 onward.
- Renegotiations of economic terms began March 5, 1993, but picketing continued; HSBC filed a ULP complaint with the NLRC.
- A strike vote was held December 19, 1993 (majority in favor); picketing and walkouts occurred December 22, 1993, with alleged obstruction of HSBC’s entry/exit.
- HSBC sought habeas corpus for trapped officers, obtained TRO and preliminary injunction (Jan 1994), and issued return-to-work notices on December 22; only 25 employees complied.
- HSBC terminated non-returning employees on December 27, 1993; the Union officers and some members persisted in picketing.
- Adjudications Below
- Labor Arbiter (1998) declared the strike illegal for non-compliance with Article 263 (no notice, no cooling-off, no secret ballot report) and ordered dismissal of participants and P45,000 damages.
- NLRC modified: found 18 members not proven to have committed illegal acts; ordered for those 18 only P5,000 indemnity and separation pay.
- Court of Appeals (2002) deleted indemnity award; granted backwages under Serrano doctrine to the 18 employees; denied reconsideration.
Issues:
- Was the strike of December 22, 1993 lawfully conducted?
- Were the petitioners validly dismissed for participating in that strike or in illegal acts therein?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)