Case Digest (G.R. No. L-5121)
Facts:
On July 12, 1948, a dispute arose between the National Labor Union (respondent), a labor organization established under Commonwealth Act 213, and J.P. Heilbronn Co. (petitioner), a domestic corporation based in Manila. The case was registered as "National Labor Union, petitioner, vs. J.P. Heilbronn Co., respondent, Case No. 160-V" in the Court of Industrial Relations (CIR). During the proceedings, Armando Ocampo and Protacio Ty, who served as President and Secretary of the local union affiliated with the National Labor Union, participated in various hearings and conferences. Subsequently, the National Labor Union filed a motion requesting the CIR to order J.P. Heilbronn Co. to reimburse Ocampo and Ty for salary deductions amounting to P88 and P64.65, respectively, for the days they were absent from work while attending these hearings. The CIR, presided over by Associate Judge V. Jimenez Yanson, granted the motion despite the company's opposition. When the compan...
Case Digest (G.R. No. L-5121)
Facts:
Parties Involved: The case involves J.P. Heilbronn Co. (the Company), a domestic corporation, and the National Labor Union (NLU), a labor organization.
Background: On July 12, 1948, the Secretary of Labor certified a labor dispute between the NLU and the Company to the Court of Industrial Relations (CIR), docketed as Case No. 160-V.
Incidental Issue: During the hearings of the case, Armando Ocampo and Protacio Ty, President and Secretary of the J.P. Heilbronn Employees Association (affiliated with NLU), attended conferences and hearings before the CIR, sometimes assisting their lawyer.
Claims: The NLU, on behalf of Ocampo and Ty, filed a motion requesting the Company to reimburse P88 and P64.65, respectively, corresponding to the salary deductions made by the Company for their absences while attending the hearings.
CIR Decision: The CIR, through Associate Judge V. Jimenez Yanson, granted the motion. The Company’s petition for reconsideration was denied, prompting the appeal to the Supreme Court.
Issue:
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Ruling:
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Ratio:
- Principle of "Fair Day’s Wage for a Fair Day’s Labor": Wages are compensation for work performed. If no work is done, there is no entitlement to wages unless the absence is due to illegal actions by the employer (e.g., wrongful dismissal or lockout).
- Precedents on Strikes: The CIR had previously ruled in similar cases (e.g., San Miguel Brewery, Inc. vs. National Labor Union and Federacion Obrera de Filipinas vs. Philippine Rubber Project Co., Inc.) that strikers are not entitled to wages for days they did not work, even if the strike was legal.
- Voluntary Absence: Employees who voluntarily absent themselves from work to attend hearings or conferences related to a labor dispute are not entitled to reimbursement for lost wages.
- Alternative Remedies: Such employees may seek reimbursement from their union or charge their absences against their vacation leave. Additionally, salary deductions could be considered as potential damages if the labor case is decided in their favor.
- Equitable Considerations: It is unjust for employees to litigate against their employer on the employer’s time, as this disrupts the equitable balance between labor and management.