Case Digest (G.R. No. 113907) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Malayang Samahan ng mga Manggagawa sa M. Greenfield (MSMG-UWP) et al. v. NLRC et al. (G.R. No. 113907, February 28, 2000), petitioners were officers and members of a local union (MSMG) affiliated with the United Lumber and General Workers of the Philippines (ULGWP). Under a collective bargaining agreement effective July 1, 1986, the employer, M. Greenfield, Inc., agreed to a union security clause requiring continued membership as a condition of employment. In April 1988, the local fined absent members ₱50 for missing a general meeting and sought wage deductions; the federation disapproved and tensions led the local to declare general autonomy. The federation placed MSMG under trusteeship in October 1988 and expelled thirty union officers on November 21, 1988, alleging disloyalty under its constitution. Relying on the federation’s recommendation, the company summarily dismissed these officers the next day without prior hearing, and later excluded several stewards and striking Case Digest (G.R. No. 113907) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Collective Bargaining Agreement
- Petitioners: Malayang Samahan ng mga Manggagawa sa M. Greenfield (MSMG-UWP) and its officers (including Beda Magdalena Villanueva et al.).
- Respondents: M. Greenfield, Inc. (B) (the Company), its officers, and United Lumber and General Workers of the Philippines (ULGWP) with its officers.
- CBA provisions:
- Article II (Union Security) – maintenance of membership; dismissal for non-payment of dues, resignation, or violation of union constitution/by-laws upon union recommendation.
- Article IX, Sec. 4 – P10,000 monthly education fund remitted to ULGWP.
- Events Leading to Dispute
- Sept. 12, 1986 – Local union election; winners proclaimed and registered.
- 1987 – Defeated candidates filed impeachment petitions and audit; dismissed for lack of evidence.
- April 17, 1988 – General membership meeting; 356 members failed to attend; local imposed P50 fines per member.
- July 1988 – Federation disapproved fines; local declared autonomy; federation withheld education funds.
- Aug.–Oct. 1988 – Company’s interpleader; Med-Arbiter ordered split of education fund (P5,000 each) and authorized collection of fines.
- Sept.–Nov. 1988 – ULGWP placed local under trusteeship; expelled 30 union officers effective Nov. 21, 1988.
- March 7, 1989 – Company, at federation’s demand under CBA union-security clause, dismissed the 30 expelled officers without separate company hearing.
- Subsequent Actions and Strike
- March 13-14, 1989 – Preventive suspension of 78 shop stewards; petitioners filed unfair-labor-practice (ULP) complaint.
- March 8, 1989 – Petitioners served strike notice; March 9 – strike ballot: 2,086 of 2,103 voted for strike.
- March 14 – Strike declared; incidents of violence occurred; company sent return-to-work notices (March 27, April 11, April 21).
- May 17, 1989 – Company terminated non-respondents for alleged abandonment.
- Aug. 7, 1989 – Petitioners filed verified ULP complaint before DOLE.
- Dec. 15, 1992 – Labor Arbiter Ramos dismissed complaint, upholding dismissals under CBA.
- NLRC First Division affirmed; SC certiorari filed alleging NLRC grave abuse of discretion.
Issues:
- Whether the dismissal of the 30 union officers pursuant to the union security clause was valid and lawful.
- Whether due process (notice and hearing) was required and observed before dismissal.
- Whether the subsequent collective strike was illegal.
- Whether the mass terminations for purported abandonment were valid.
- Whether private and public respondents committed unfair labor practices.
- Proper remedies for terminated employees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)