Title
Master Iron Labor Union vs. National Labor Relations Commission
Case
G.R. No. 92009
Decision Date
Feb 17, 1993
The Supreme Court ruled in favor of the labor union, affirming the legality of their strike and ordering the reinstatement of individual petitioners amid disputes over unfair labor practices and the corporation's retaliatory actions.
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Case Digest (G.R. No. 92009)

Facts:

  • The case involves the Master Iron Labor Union (MILU) and individual members, including Wilfredo Abulencia and Rogelio Cabana, as petitioners against the National Labor Relations Commission (NLRC) and Master Iron Works and Construction Corporation as respondents.
  • In February 1987, MILU entered into a collective bargaining agreement (CBA) with the Corporation, valid from December 1, 1986, to November 30, 1989.
  • The CBA included a no-strike provision and specified service allowances for workers assigned outside the company premises.
  • Following the CBA, the Corporation began subcontracting work typically performed by regular employees, reducing their working days to ten per month.
  • MILU attempted to implement the grievance procedure outlined in the CBA, but the Corporation ignored their requests.
  • On April 8, 1987, MILU filed a notice of strike with the Department of Labor and Employment (DOLE).
  • An agreement was reached to restore regular work, but the Corporation continued hiring outside workers.
  • On July 9, 1987, MILU filed another notice of strike citing violations of the CBA, discrimination, unreasonable suspensions of union officials, and refusal to entertain grievances.
  • The strike commenced on July 24, 1987, but was disrupted by the arrest of picketers by CAPCOM soldiers on July 28, 1987, leading to a temporary lifting of the strike.
  • The Corporation filed a petition with the NLRC to declare the strike illegal.
  • On March 16, 1988, Labor Arbiter Fernando Cinco ruled the strike illegal and ordered the termination of the individual petitioners' employment.
  • The NLRC affirmed this decision on July 12, 1989, with modifications, prompting the petitioners to seek certiorari from the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the strike was legal, based on unfair labor practices by the employer.
  • The Court found that the NLRC abused its discretion in holding that the grievance procedure was not exhausted.
  • The termination of employmen...(Unlock)

Ratio:

  • The Supreme Court emphasized that a no-strike clause in a collective bargaining agreement primarily applies to economic strikes.
  • The petitioners' strike was based on allegations of unfair labor practices, including the Corporation's violation of the CBA through subcontracting and discrimination against union me...continue reading

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