Facts:

In the case of Litex Employees Association and Domingo Rances vs. The Court of Industrial Relations, et al., (G.R. No. L-39154, September 09, 1982), Domingo Rances, a chemical mixer at Lirag Textile Mills, and a board member of the Litex Employees Association (affiliated with PTGWO) initiated the case against the respondents which included Lirag Textile Mills, Rafael Gallema, and Antonio Lorzano, among others. The background of the dispute dates back to February 10, 1972, when Rances wrote a letter to Lorzano, then president of the union, recommending that proposed amendments to their constitution be ratified and asking for the matter to be presented at the union's constitutional convention. The union president responded by claiming Rances lacked the legal authority to send such correspondence and charged him with violating particular provisions of the union’s constitution.

Subsequently, Rances failed to respond to the union's notifications and was expelled during a Boar

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Facts:

Parties and Background

• Petitioners: Litex Employees Association and Domingo Rances; Respondents: The Court of Industrial Relations, Lirag Textile Mills, and several union and company officers (including Antonio Lorzano, Rafael Gallema, and others).
• Rances was a chemical mixer at Lirag Textile Mills and also a board member of the Litex Employees Association (LEA-PTGWO).

Timeline of Events

• February 10, 1972

- Rances, in his capacity as a union board member, wrote a letter to union president Antonio G. Lorzano. - In the letter, he requested that an amendment to the union’s constitution and by-laws be considered as ratified and submitted the matter for final decision at a constitutional convention. - Union President Lorzano replied that Rances had no legal personality to issue such a letter. - The reply stated that the letter violated the union’s constitution and by-laws. - Rances was charged by the union’s Board of Directors for allegedly violating paragraphs (b) and (c) of Section 5 of the Amended Constitution and By-Laws, which pertained to: - Rances was given 72 hours to respond in writing to the charges. - Rances failed to answer within the prescribed 72 hours. - On March 1, 1972, the union’s Board of Directors resolved to expel him from the union and to recommend his dismissal from Lirag Textile Mills. - On March 2, 1972, Respondent Lorzano sent a notice affirming his expulsion from LEA-PTGWO and a recommendation for dismissal from employment. - Management was duly furnished with a copy of this notice. - On March 20, 1972, a letter was sent by a company representative requesting Rances to comment on his expulsion and dismissal, but he did not respond. - On March 29, 1972, another letter communicated that his failure to comment led to the presumption of his disinterest, effectively deeming him dismissed from the company as of April 4, 1972. - An election held on March 30, 1972, resulted in a new set of union officers. - On April 1, 1972, Rances wrote to the new union president, Johnny de Leon, requesting a reinvestigation of his expulsion. - The new Board of Directors swiftly passed Resolution No. 6, Series of 1972 (April 9, 1972), rescinding and revoking the earlier expulsion, and recommended his immediate reinstatement pursuant to the collective bargaining agreement (CBA) union security clause. - On April 11, 1972, President de Leon recommended Rances’ reinstatement to management. - Management, via Major Rafael Gallema, replied on April 14, 1972, rejecting the recommendation on the grounds that the company’s action was already final. - Further union-management grievance meetings on April 26, 1972, and May 26, 1972, generated proposals whereby the management offered Rances reinstatement as a casual employee, and later as a regular employee subject to an admission of guilt (which he refused). - On May 29, 1972, petitioners filed a charge for unfair labor practices against the respondents, alleging that his dismissal was due to union activities. - The charge (No. 5098) contended that Rances’ dismissal was directly linked to his union activities and the subsequent internal procedures. - The Acting Chief Prosecutor, Bienvenido Millares, conducted a preliminary investigation and subsequently filed a Motion to Dismiss on November 3, 1972, based on Rances’ alleged failure to exhaust internal remedies as required by Section 17 of Republic Act No. 875. - On March 2, 1973, Judge Alberto S. Veloso dismissed the unfair labor practice charge. - The decision was later affirmed by the en banc Court of Industrial Relations on July 29, 1974.

Underlying Dispute and Grounds of the Case

• Rances argued that the internal union investigation would have amounted to a farcical proceeding, as the union officers were set to act simultaneously as prosecutor, investigator, and judge.
• He maintained that his letter, which highlighted voting irregularities and questioned certain provisions of the union’s constitution, was a rightful exercise of his rights under Republic Act No. 875.
• The petitioners contended that the dismissal resulted from union political maneuvers rather than genuine misconduct, making the dismissal an unfair labor practice.
• The central issue involved whether the internal exhaustion of remedies requirement was absolute, particularly when such procedures undermine the proper administration of justice.

Issue:

Compliance with Internal Procedures

• Whether Rances was required to exhaust internal union remedies as stipulated in the union’s constitution and by-laws before seeking judicial redress.
• Whether those internal procedures were, in fact, available or merely illusory, considering the potential conflict of roles (prosecutor, investigator, and judge).

Nature of the Alleged Misconduct

• Whether the content and nature of Rances’ February 10, 1972 letter constituted a violation of the constitutional provisions of the union, specifically regarding the refusal to obey internal rules and actions prejudicial to the union’s interests.

Justification of Dismissal and Expulsion

• Whether the expulsion from the union and subsequent dismissal from employment were warranted actions given that they were motivated by internal union politics rather than bona fide disciplinary grounds.
• Whether the dismissal constituted an unfair labor practice under the applicable legal standards.

Management’s Reassessment of Final Acts

• Whether the management’s later proposals of reinstatement (first as a casual employee and then as a regular employee subject to conditions) impacted the finality of the dismissal.
• Whether revisiting internal union actions following a change in leadership negates the supposed finality cited by the management.

Consistency with Prior Jurisprudence

• Whether the decision to dismiss the unfair labor practice charge, based on the failure to exhaust internal remedies, aligns with precedents that allow exceptions when internal procedures result in a denial of justice.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)