Case Digest (G.R. No. L-1573)
Facts:
Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas v. Gotamco Saw Mills, G.R. No. L-1573, March 29, 1948, the Supreme Court En Banc, Hilado, J., writing for the Court.The petitioning union, Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas (petitioner-appellant), challenged several orders and a resolution of the Court of Industrial Relations (CIR): the order of September 23, 1946; the order of March 28, 1947 (entered after proceedings in January 1947); and the CIR resolution of July 11, 1947 denying reconsideration. The petition to the Supreme Court sought a writ of certiorari to reverse and vacate those CIR dispositions.
The underlying controversy began with a strike by the mill laborers, declared September 10, 1946, which halted operations at Gotamco Saw Mills (respondent-appellee). The CIR conducted preliminary conferences and hearings. By its September 23, 1946 order the CIR recorded that after negotiation the parties agreed on a temporary settlement: an over-all wage increase of P2.00 daily without meal, permission for laborers to take small pieces of lumber for firewood if available, and that the arrangement would be effective upon return to work pending final determination. The CIR approved that temporary agreement and ordered the striking laborers to resume work on September 24, 1946; it enjoined the company from dismissing union members and enjoined the union from staging further strikes during the hearing.
On January 7–9, 1947 the respondent filed motions for contempt alleging the union staged a strike in violation of the September 23 order and picketing that interfered with work; the union counter-petitioned for contempt against respondent for employing four Chinese laborers during the pendency of the main case in alleged violation of Section 19 of Commonwealth Act No. 103, as amended. The CIR required evidence and, in its March 28, 1947 order, framed issues whether the union had violated the September 23 order (warranting contempt), whether picketing constituted contempt, whether respondent had violated Section 19 by hiring the four Chinese laborers, and whether the dismissal of one Maximino Millan was with cause. The CIR concluded that the union had violated its September 23 order and directed its special agent to take appropriate action for contempt; it did not find clear proof of respondent’s Section 19 violation and therefore exonerated the respondent regarding the Chinese hires; and it denied Millan’s petition for reinstatement.
The CIR, sitting in banc (full court), denied the union’s motion for reconsideration in its July 11, 1947 resolution. The CIR further addressed the union’s argument that the September 23 order failed to satisfy Section 19’s requisites because it lacked an express finding that public interest required the return order and because there had been no proper hearing; the CIR held the order was issued after preliminary hearings and that the record showed the dispute could not be promptly decided or settled, so the order was lawful. The CIR also defended Section 19 as constitutional.
The union brought a petition for a writ of certiorari to the Supreme Court seeking review of the CIR orders and resolution. The Supreme Court consid...(Pro-only)
Issues:
- May the Supreme Court revise the findings of fact made by the Court of Industrial Relations?
- Is Section 19 of Commonwealth Act No. 103 constitutional, specifically whether it violates the constitutional prohibition against involuntary servitude?
- Did the Court of Industrial Relations act within Section 19 and its powers in issuing the September 23, 1946 return-to-work order, in finding the union in contempt, in declining to punish the respondent for hiring Chinese laborers, and ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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