G.R. No. L-33987 - Liberty Cotton Mills Workers Union vs. Liberty Cotton Mills, Inc.

Petitioners – the Liberty Cotton Mills Workers Union and individual union members Rafael Nepomuceno, Mariano Castillo, Nelly Acevedo, Rizalino Castillo, and Rafael Combalicer – filed a motion for reconsideration and/or modification of the decision dated September 4, 1975.
The motion, filed on September 24, 1975, sought:

Joint and several liability imposed on the respondent company for the payment of backwages.
Immediate reinstatement of the workers without loss of seniority or fringe benefits, at the same wage rates as in 1964.
Payment of backwages for more than three years without deduction or, alternatively, a minimum of 50% backwages for the period from dismissal to actual reinstatement.

The Court, in its resolution dated September 29, 1975, required the respondents to file their comments. Subsequent manifestations of compliance and comments were filed by Liberty Cotton Mills, Inc., the Philippine Association of Free Labor Union (PAFLU), and the National Labor Relations Commission (successor of the Court of Industrial Relations).

On May 17, 1964, thirty-two out of thirty-six members of the Liberty Cotton Mills Local Union disaffiliated from the Philippine Association of Free Labor Union (PAFLU) in accordance with the local union’s Constitution and By-Laws.
PAFLU received the disaffiliation resolution on May 25, 1964, but immediately declared it null and void, asserting its right to administer the local union’s affairs.

On May 27, 1964, PAFLU informed the respondent company that the disaffiliation was ineffective and that it was assuming control over the union.
On May 29, 1964, PAFLU advised the company to expel the petitioner workers – allegedly for acts of disloyalty and unbecoming conduct for instigating the disaffiliation.
The respondent company, relying on the Maintenance of Membership provision of the Collective Bargaining Agreement, terminated the employment of the petitioner workers on May 30, 1964, without affording them any opportunity for a hearing.

The dismissal was executed with “scandalous haste” and in a summary manner that denied the workers the benefit of a hearing.
The company acted immediately on PAFLU’s request, disregarding inquiries from the workers and even PAFLU regarding the true cause of expulsion.
The record reveals a pattern of procedural injustice, as after the dismissal, petitioners’ request for reconsideration was summarily denied on June 2, 1964, without valid justification.
The Court observed that the company’s conduct, particularly its rapid compliance with PAFLU’s request, evidences bad faith and possibly a conspiracy or connivance between the respondent company and PAFLU.

Whether the immediate, summary dismissal of the petitioner workers, on the basis of PAFLU’s request, violated their constitutional right to due process and security of tenure.
Whether the respondent company acted in bad faith in effecting the dismissal by neglecting to provide the workers with a hearing and proper inquiry into the circumstances.
Whether a showing of conspiracy or connivance between the respondent company and PAFLU in the dismissal corroborates the claim of illegal dismissal.
Whether the respondent company should be held jointly and severally liable with PAFLU for the payment of backwages.
Whether the award of three (3) years’ backwages without deduction or qualification, following the established formula from previous cases, is just and proper under the facts.