Title
Liberty Cotton Mills Workers Union vs. Liberty Cotton Mills, Inc.
Case
G.R. No. L-33987
Decision Date
Sep 4, 1975
Workers disaffiliated from PAFLU, leading to unjustified dismissal; Supreme Court ruled disaffiliation valid, ordered reinstatement, and held PAFLU liable for back wages.

Case Digest (G.R. No. L-33987)
Expanded Legal Reasoning Model

Facts:

  • Background and Union Organization
    • The Liberty Cotton Mills Workers Union (hereinafter, the Union) adopted its Constitution and By-Laws on January 1, 1959.
    • The Constitution provided the union’s name, domicile, and key provisions regarding union affiliation, charges, trials, impeachment of officers and members, and definitions of roles and powers.
    • Article I and Article X of the Constitution and By-Laws specifically defined the union’s name and its affiliation with the Philippine Association of Free Labor Unions (PAFLU), as well as the conditions for maintaining such affiliation.
  • Collective Bargaining Agreements
    • On October 1, 1959, a Collective Bargaining Agreement (CBA) was executed between the Company (Liberty Cotton Mills, Inc.) and the Union represented by PAFLU.
      • The CBA contained clear provisions:
        • Recognition of the Union as the sole bargaining agent for all employees except supervisors and security guards.
ii. A union security clause mandating that all employees sign on as union members and remain so as a condition for continued employment. iii. A term clause specifying the duration from October 1, 1959 to September 30, 1961, with provisions for renewal if no notice for amendment or discontinuance was given.
  • On February 28, 1964, the CBA was amended to include:
    • An additional clause under Article III to encourage casual workers and non-union members to join the Union.
    • A revised duration setting the agreement from November 2, 1963, up to November 1965.
  • Disaffiliation and Internal Union Conflict
    • On March 13, 1964, while the CBA was still in effect, the local union officers (Marciano Castillo and Rafael Nepomuceno) lodged a complaint with PAFLU regarding the legal counsel assigned to them in a case (Case No. 4001) against the Company.
    • On May 17, 1964, 32 out of 36 union members executed a resolution disaffiliating the local union from PAFLU, invoking the provisions of Article X of the union’s Constitution and By-Laws.
      • A signed copy of the resolution was furnished to both the Company and the Bureau of Labor Relations.
    • Following the resolution, on May 18, 1964, the local union instructed the Company to turn over the union dues directly to its Treasurer.
  • PAFLU’s Response and Subsequent Communications
    • On May 27, 1964, PAFLU, through its National Secretary, sent a letter to the Company stating:
      • The disaffiliation was invalid under the existing contract and the PAFLU Constitution and By-Laws.
      • The local union, as expressed in the CBA, remained the contractual union.
      • The letter referenced the “Maintenance of Union Membership” clause and threatened dismissal of members deemed disloyal.
    • On May 29, 1964, PAFLU reiterated its stand by quoting the union security provision of the CBA and explicitly requested the termination of the petitioners (including Rafael Nepomuceno, Marciano Castillo, Nelly Acevedo, Enrique Managan, Rizalino Castillo, and Rafael Combalicer) for their role in instigating the disaffiliation.
  • Termination of Employment and Filing of Complaint
    • On May 30, 1964, acting on PAFLU’s request, the Company dismissed the petitioners based on the alleged act of disloyalty and the disaffiliation from PAFLU.
    • Later that same month, counsel for the terminated workers sought their reinstatement by filing a complaint for unfair labor practice before the Court of Industrial Relations.
    • After due hearings, the Court of Industrial Relations dismissed the complaint but strongly recommended the reinstatement of the workers.
  • Issues Raised by the Petitioners
    • Petitioners appealed the decision, raising multiple questions regarding:
      • The identity of the sole bargaining agent under the CBA—whether PAFLU or the local union.
      • The validity and justification of the disaffiliation from PAFLU under the union’s Constitution and By-Laws.
      • Whether the act of disaffiliation constituted disloyalty warranting both expulsion from the union and dismissal.
      • PAFLU’s power under its own Constitution and By-Laws to expel officers and members.
      • The propriety of dismissals carried out summarily under the terms of the CBA, especially in view of the timing and the process involved.

Issues:

  • Who, under the Collective Bargaining Agreement, is deemed the sole bargaining agent for the Company’s employees—the PAFLU or the local union?
  • Was the disaffiliation of the local union from PAFLU valid and justified under the union’s Constitution and By-Laws?
  • Can the act of disaffiliation be equated with disloyalty by the petitioners, thereby justifying both their expulsion from the union and their dismissal from employment?
  • Does PAFLU, as the mother federation of the union, possess the constitutional and by-law authority to expel union officers and members?
  • Was the dismissal of the complaining workers justifiable under the terms of the Collective Bargaining Agreement, given the absence of valid and timely retraction by all union members?
  • Does the selective dismissal of only five petitioners, despite the overwhelming majority’s resolution for disaffiliation, amount to discriminatory practice?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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