G.R. No. 198609-10 - Department of Fice and Department of Energy vs. Philippine Airlines, Inc.

The laborers employed by Gotamco Saw Mills declared a strike on September 10, 1946, halting all work in the respondent company.
The Court of Industrial Relations (CIR) intervened, informing both parties on September 19, 1946, that continuation of the strike would prejudice both parties and urged them to find a temporary solution.
Conferences were held until September 21, 1946, when the labor leader agreed to a temporary wage settlement, although not fully satisfactory to the workers, to resume work and operations.
On September 23, 1946, the CIR issued an order approving a temporary agreement: laborers would receive a daily over-all increase of P2.00 without meals; laborers were allowed to take small pieces of lumber home as firewood; these conditions would be effective upon their return to work pending final disposition of the dispute.
The CIR enjoined the company from laying off or dismissing union laborers and the union from striking during the pendency of the case.

On January 7, 1947, the respondent company filed a motion to hold the union in contempt for striking despite the September 23, 1946, order.
The union answered on January 9, 1947, alleging discriminatory practices by the company and counter-accused the company of contempt for unlawfully employing four Chinese workers during the pendency of the dispute in violation of Section 19 of Commonwealth Act No. 103.
The respondent filed another contempt motion the same day for union picketing and threats that prevented laborers from working.
The CIR required presentation of evidence on these issues.

Found the union violated the September 23, 1946 order and recommended contempt proceedings against responsible persons.
Declined to separately rule on picketing as it was integrally related to the strike.
Found no compelling evidence the company violated Section 19 of Commonwealth Act No. 103 regarding hiring Chinese laborers.
Denied the reinstatement petition of a troublesome worker, Maximino Millan.

The July 11, 1947 CIR resolution denied the union’s motion for reconsideration and addressed the validity and constitutionality of Section 19 of Commonwealth Act No. 103 as applied in the case.

The union argued that the September 23, 1946 order was invalid because it was not issued after proper hearings and without a court finding that public interest required the workers’ return, as mandated by Section 19.
Further, the union challenged Section 19 itself as unconstitutional, claiming it imposed involuntary servitude.

The Supreme Court acknowledged that the order was based on agreements after preliminary hearings and that the Court of Industrial Relations did not need to restate the court’s finding on public interest explicitly in the order since the dispute remained unresolved and hearings were ongoing.
It took judicial notice of the national public interest in lumber production for postwar reconstruction, justifying preventing undue stoppages.
The Court noted that Section 19 authorized such orders pending decision or settlement and that the union benefited from and accepted the order’s provisions before challenging its validity.
The Court upheld the constitutionality of Section 19 and rejected the involuntary servitude argument, reasoning that workers voluntarily entered into contracts subject to its conditions.

Whether the Court of Industrial Relations’ order of September 23, 1946, approving a temporary wage settlement and ordering the union workers to return to work was valid and issued in compliance with Section 19 of Commonwealth Act No. 103.

Whether the petitioning union’s violation of the CIR’s order by staging a strike and picketing during the pendency of the case constituted contempt of court.

Whether the respondent company violated Section 19 of Commonwealth Act No. 103 by employing four Chinese laborers during the pendency of the case without CIR authorization.

Whether Section 19 of Commonwealth Act No. 103, as amended, is constitutional, particularly addressing the claim that it violates the constitutional prohibition against involuntary servitude.

Whether the Supreme Court has authority to review findings of fact made by the Court of Industrial Relations.