Case Digest (G.R. No. L-23495)
Facts:
LVN Pictures Employees and Workers Association (NLU) v. LVN Pictures, Inc., G.R. Nos. L-23495 & L-26432, September 30, 1970, the Supreme Court En Banc, Castro, J., writing for the Court. These consolidated appeals by certiorari challenge decisions and resolutions of the Court of Industrial Relations (CIR) in two unfair labor practice cases: case 2879-ULP (decisions dated October 3, 1963 and resolution August 29, 1964) and case 3013-ULP (decision dated June 2, 1966 and resolution July 18, 1966).Petitioners are the LVN Pictures Employees and Workers Association (NLU) (EWA) and the LVN Pictures Checkers' Union (NLU) (LPCU); respondents are LVN Pictures, Inc. (LVN) and Dalisay Pictures, Inc. (DPI), with the CIR as the tribunal whose rulings were appealed. The EWA consisted of technical and production personnel; the LPCU consisted of theater checkers.
LVN produced Tagalog films and had a collective bargaining agreement with the EWA effective April 23, 1959 to December 31, 1960. From 1957 to 1961 LVN suffered heavy financial losses, culminating in net losses that exceeded paid-up capital and depletion of overdraft lines as of May 31, 1961. To avoid immediate closure and layoffs LVN proposed alternatives: on March 14, 1960 it proposed converting pay to a "pakiao" (per-picture) system (rejected by EWA), and on January 25, 1961 it proposed graduated salary reductions (also rejected). After the collective-bargaining term expired, LVN delayed answers to bargaining proposals pending a stockholders' meeting; on March 20, 1961 the company informed the EWA it would await the stockholders' decision, and by March 20 (later communicated) the stockholders resolved to stop producing new pictures and to close movie production effective May 31, 1961.
As a result LVN dismissed production personnel (including 84 EWA members). LVN retained a skeleton force to safeguard property and thereafter leased studio equipment and facilities to independent producers (who employed their own crews, sometimes hiring former LVN workers). On May 31, 1961 Dalisay Pictures, Inc. was incorporated with capital subscribed by persons not identified as LVN owners.
The EWA filed a complaint before the CIR on July 18, 1961, alleging violations of section 4(a)(1) and (4) of Republic Act No. 875 (Industrial Peace Act) for union interference and discriminatory dismissals. The LPCU filed a complaint on October 20, 1961 against LVN and DPI alleging violations of sec. 4(a)(1), (4) and (6) in relation to secs. 12 and 13 of the Industrial Peace Act, charging discri...(Pro-only)
Issues:
- Did LVN commit an unfair labor practice by dismissing employees who were members of the EWA and the LPCU?
- Are LVN Pictures, Inc. and Dalisay Pictures, Inc. one and the same corporation or separate and di...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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