Facts:

The case involves Itogon-Suyoc Mines, Inc. (petitioner) and the Sangilo-Itogon Workers' Union (respondent) on behalf of Bartolome Mayo, Bernardo Aquino, and thirteen other individuals. The events leading to the case began prior to May 28, 1958, when the petitioner, through its general superintendent Claude Fertig, dismissed members of the Sangilo union. By this time, fifty-four members had already been terminated. In response to the ongoing dismissals, the Sangilo union called for a strike on May 28, 1958, which resulted in a complete work stoppage at the mine. The strike lasted until June 2, 1958, when the petitioner filed an injunction against some strikers in the Court of First Instance of Baguio. On the same day, the petitioner reached an agreement with another labor union, the Itogon Labor Union, which included a notice to strikers to return to work within fifteen days, although this notice did not mention the grace period.

On November 18, 1958, a complaint was fi...

Facts:

Background of the Case

The case involves Itogon-Suyoc Mines, Inc. (petitioner) and the Sangilo-Itogon Workers' Union (respondent union) representing fifteen dismissed employees. The controversy arose from the dismissal of union members, which led to a strike and subsequent legal actions.

Dismissal of Union Members

Prior to May 28, 1958, the petitioner, through its general superintendent Claude Fertig, dismissed 54 members of the respondent union. The union alleged that these dismissals were part of a strategy to eliminate union members from the company.

Strike and Picketing

On May 28, 1958, the union called a strike, accompanied by peaceful picketing at the company's mine premises in Itogon. The strike paralyzed work, and on the fourth or fifth day, company policemen drove the strikers out of the premises. The strike lasted until June 2, 1958.

Injunction Suit and Agreement

On June 2, 1958, the petitioner filed an injunction suit against some strikers in the Court of First Instance of Baguio. On the same day, the company reached an agreement with another labor union, the Itogon Labor Union, giving strikers 15 days to return to work. However, notices posted by the company did not mention the 15-day grace period.

Unfair Labor Practice Charges

On November 18, 1958, the Court of Industrial Relations (CIR) prosecutor charged the petitioner with unfair labor practice for dismissing two employees, A. Manaois and Jose Baldo, allegedly due to their union affiliation. The CIR ruled that the dismissal of Manaois was justified but found the dismissal of Baldo to be an unfair labor practice, ordering his reinstatement with back wages.

Second Unfair Labor Practice Complaint

On July 12, 1960, the CIR prosecutor filed another unfair labor practice complaint against the petitioner, Claude Fertig, and the Itogon Labor Union, alleging the arbitrary dismissal of 107 union members. The complaint sought reinstatement, back wages, and the dissolution of the Itogon Labor Union, which was accused of being company-dominated.

CIR Decision

On May 20, 1964, the CIR ruled that the strike was peaceful and justified, as the union members were being gradually dismissed. The CIR ordered the reinstatement of 15 employees with full back wages but dismissed the charges against the Itogon Labor Union.

Issue:

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Ruling:

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Ratio:

1. Capacity to Sue: A labor union retains its legal capacity to sue unless its registration is finally cancelled. The absence of a final cancellation order means the union can still represent its members in legal proceedings.
2. Splitting of Cause of Action: The rule against splitting a cause of action applies only when the same parties and issues are involved. Here, the two cases involved different employees and circumstances, making them distinct causes of action.
3. Laches: Laches requires unreasonable delay and prejudice to the defendant. The 15 individual respondents actively pursued their claims, and the delay was partly due to the company's actions, so laches did not apply.
4. Reinstatement and Back Wages: Employees dismissed due to unfair labor practices are entitled to reinstatement and back wages. However, back wages should be reduced by any earnings from other employment during the dismissal period to prevent double compensation.

Conclusion:

The Supreme Court upheld the CIR's decision, affirming the reinstatement of the 15 employees with back wages, subject to deductions for other earnings. The Court rejected the petitioner's arguments regarding the union's capacity to sue, splitting of the cause of action, and laches, emphasizing the importance of protecting workers' rights against unfair labor practices.