G.R. No. 128448 - Spouses Mirasol vs. Court of Appeals

First Philippine Scales, Inc. (FPSI) employed petitioners Herminigildo Inguillo and Zenaida Bergante as assemblers in 1977 and 1986 respectively.
In 1991, FPSI and the First Philippine Scales Industries Labor Union (FPSILU) entered into a Collective Bargaining Agreement (CBA) effective from September 12, 1991, to September 12, 1996.
Both Bergante and Inguillo were members of FPSILU and ratified the CBA by signing the ratification document.

During the CBA’s validity, Bergante, Inguillo, and others joined another union, Nagkakaisang Lakas ng Manggagawa (NLM), affiliated with KATIPUNAN.
NLM-KATIPUNAN filed an intra-union dispute with the Department of Labor and Employment (DOLE) against FPSILU and FPSI. The Med-Arbiter ruled in favor of FPSILU and ordered NLM-KATIPUNAN to return P90,000.00 union dues from employees.
A Writ of Execution was issued; part of the amount was recovered via garnishment from employees’ earnings, including Inguillo's salary.

On March 18, 1996, FPSILU’s executive board petitioned FPSI’s General Manager Amparo Policarpio to terminate several employees, including Bergante and Inguillo, for disloyalty and other grounds such as dereliction of duty and damage to production.
FPSI terminated the employees on May 16, 1996, following the Union’s recommendation.
Subsequently, Inguillo filed a complaint for illegal withholding of salary and illegal dismissal; consolidated complaints were filed by petitioners and other union members.

Labor Arbiter Manuel Manansala dismissed Bergante and Inguillo’s complaints, ruling their dismissal valid for violating the Union Security Clause by disaffiliating from FPSILU and joining a rival union.
FPSI was ordered to pay separation pay and legal holiday pay.

NLRC reversed the Labor Arbiter’s decision, ordering reinstatement with full back wages and payment of withheld salary for Inguillo.
On reconsideration, the NLRC reversed itself and upheld the dismissal as valid enforcement of the Union Security Clause, ordering payment of withheld salary and attorney’s fees only.

Bergante and Inguillo filed a petition for certiorari, which the CA dismissed, sustaining the NLRC ruling that the dismissal was justified under the Union Security Clause.
The CA recognized the union security clause as a valid closed-shop arrangement, not violating the freedom of association.

The Supreme Court affirmed the validity of the dismissal based on the enforcement of the Union Security Clause.
However, it ruled there was a failure to observe procedural due process, specifically the lack of proper notice and hearing prior to dismissal.
As a remedy, the Court ordered nominal damages of P30,000.00 each in favor of Bergante and Inguillo.

Whether the dismissal of Bergante and Inguillo based on the Union Security Clause in the CBA was valid.
Whether respondents complied with procedural due process requirements in effectuating the dismissal.
Whether failure to observe procedural due process renders the dismissal illegal or ineffective.