Case Digest (G.R. No. L-20764)
Facts:
Santos Juat v. Court of Industrial Relations, G.R. No. L-20764. November 29, 1965, the Supreme Court En Banc, Zaldivar, J., writing for the Court.Petitioner Santos Juat had been employed by Bulaklak Publications since August 1953. On December 1, 1959 Bulaklak Publications and the Busocope Labor Union entered into a collective bargaining agreement containing a closed‑shop provision; that provision was amended December 27, 1960 to require that employees who were not union members on January 1, 1961 become members as a condition of continued employment. Beginning about July 15, 1960, Juat was repeatedly asked to join the Busocope union but refused.
Acting Prosecutor Alberto Cruz of the Court of Industrial Relations (CIR) filed a complaint as Case No. 2889‑ULP charging Bulaklak Publications and/or Juan N. Evangelista with unfair labor practice under Section 4(a) (subsections 1, 4 and 5) of Republic Act No. 875, alleging Juat’s suspension and eventual dismissal without justifiable cause and that Juat had, after his dismissal, been unable to obtain substantial employment. Juat had also filed separate petitions (one for unfair labor practice and another for unpaid wages) whose filing and dates figure in the parties’ pleadings and defenses.
Respondents answered alleging Juat was suspended and later dismissed for cause: refusal to join the union in accordance with the closed‑shop agreement and, after a 15‑day suspension, refusal to report for work when ordered; they further asserted Juat had his own printing business. After hearing, Associate Judge Baltazar N. Villanueva of the CIR rendered a decision dated August 15, 1962 dismissing Juat’s complaint (the decision did not dispose of the counterclaim). The CIR en banc denied Juat’s motion for reconsideration in a resolution dated October 30, 1962. Juat then filed a petition for certiorari with the Supreme Court to review the CIR’s decision and the en banc resolution.
The CIR’s findings (adopted and summarized by the Supreme Court) were: the closed‑shop clause was valid and operated as the “law between the parties”; Juat, though an old employee, was not a union member at the time the collective bargaining agreement was made and therefore could be required to join; Juat was suspended for 15 days for refusing to join, failed to return to work upon order, and was dropped from the service; Juat also had his own business and thus had alternative employment; accordingly, Bul...(Subscriber-Only)
Issues:
- Did the Court of Industrial Relations commit grave abuse of discretion in applying a closed‑shop proviso of a collective bargaining agreement to petitioner, an “old employee” who was not a union member when the agreement was made?
- Did the Court of Industrial Relations err in holding that Bulaklak Publications did not commit an unfair labor practice by dismissing petitioner for his refusal to join the Busocope Labor Union?
- Did the Court of Industrial Relations commit grave abuse of discretion in dismissing petition...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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