Case Digest (G.R. No. 123938) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Labor Congress of the Philippines (LCP) et al. v. NLRC et al., decided on May 21, 1998, ninety-nine rank-and-file employees of Empire Food Products, Inc. (petitioners) represented by the Labor Congress of the Philippines entered into a Memorandum of Agreement with proprietors Gonzalo and Evelyn Kehyeng on October 23, 1990, recognizing LCP as the sole and exclusive bargaining agent. Mediator Arbiter Cortez approved the agreement on October 24, 1990. On January 23, 1991, petitioners filed before the Labor Arbiter a complaint for: illegal lockout/dismissal, unfair labor practices, union busting, violation of the MOA, underpayment of wages under R.A. Nos. 6640 and 6727, and damages. Labor Arbiter Ariel C. Santos initially dismissed the complaint for lack of merit but ordered reinstatement for a technical breach of payroll record-keeping. On appeal, the NLRC remanded for further proceedings, finding the Arbiter had overlooked petitioner testimony. On July 27, 1994, the Arbiter aga Case Digest (G.R. No. 123938) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Ninety-nine (99) rank-and-file employees of Empire Food Products represented by the Labor Congress of the Philippines (LCP).
- Respondents: Empire Food Products (employer), Gonzalo Kehyeng and Evelyn Kehyeng (management), National Labor Relations Commission (NLRC).
- Initial claims:
- Money claims and violations of labor standards (NLRC RAB-III-10-1817-90).
- Direct certification petition of LCP as bargaining representative (Case No. R0300-9010-RU-005).
- Procedural History
- October 23, 1990 – Memorandum of Agreement (MOA) signed:
- LCP recognized as sole and exclusive bargaining agent; provisional withdrawal of NLRC case; wage adjustment; union-dues check-off; agreement to negotiate CBA.
- MOA approved by Mediator-Arbiter on October 24, 1990.
- January 23, 1991 – Petitioners filed complaint for unfair labor practice, illegal lockout/dismissal, union busting, underpayment of wages, and damages (NLRC RAB-III-01-1964-91).
- April 14, 1992 – Labor Arbiter’s Decision: dismissed private respondents from all charges except technical violation for failing to keep payroll records; directed reinstatement of complainants.
- July 21, 1992 – NLRC Resolution: vacated Decision, remanded for further proceedings, noting overlooked testimonies and lack of dispositive portion.
- July 27, 1994 – Labor Arbiter’s Second Decision: dismissed complaint for lack of proof of unfair labor practice, held petitioners abandoned their work (based on single-day absence), denied damages.
- March 29, 1995 – NLRC Resolution: affirmed Labor Arbiter’s dismissal in toto; denied reconsideration on October 31, 1995.
- December 1995 – Petitioners filed special civil action for certiorari under Rule 65 before the Supreme Court.
- Office of the Solicitor General (OSG) intervened, supporting petitioners on the issue of abandonment and non-reinstatement.
Issues:
- Did the NLRC gravely abuse its discretion by ignoring favorable evidence, applicable jurisprudence, and due process?
- Were petitioners deprived of constitutional rights to self-organization, security of tenure, protection of labor, and just conditions of work?
- Were petitioners illegally dismissed or constructively dismissed by being deemed to have abandoned their work?
- Are petitioners entitled to reinstatement (or separation pay), back wages, statutory benefits, damages, and attorneys’ fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)