Title
National Federation of Labor vs. National Labor Relations Commission
Case
G.R. No. 113466
Decision Date
Dec 15, 1997
Workers' illegal strike, barricading, and refusal to comply with return-to-work order justified dismissal; NLRC upheld, damages awarded to employer.

Case Digest (G.R. No. 113466)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved
    • Petitioners
      • National Federation of Labor (NFL), a legitimate labor federation represented by its Regional Director for Western Mindanao, Amado Magbanua.
      • 141 dismissed union members who were employees of the respondent corporation.
    • Respondents
      • PERMEX Producer and Exporter Corporation, a Zamboanga City-based company engaged in the fish and tuna export business.
      • Corporate officers of PERMEX, who were co-respondents in the case.
  • Background and Nature of the Dispute
    • The dispute arose from an alleged illegal strike and unfair labor practices.
      • NFL contended that union officials were unjustly barred from company premises and subsequently disciplined for engaging in union activities.
      • The issues involved claims of unlawfully preventing entry into the corporation, unwarranted disciplinary measures, and damages arising from these actions.
    • The procedural history involved two separate cases filed before the NLRC:
      • NLRC Case No. RAB 09-02-00062-93 filed by PERMEX to have the strike declared illegal.
      • NLRC Case No. RAB 09-02-00069-93 filed by NFL against PERMEX alleging unfair labor practice, with claims for damages and backwages.
  • Chronology of Events
    • Pre-strike Events
      • On January 23, 1993, NFL asserted that ten union officials, who attended a scheduled pre-election conference, were barred from entering the company premises allegedly due to their union activities.
      • The NLRC, however, found that the matter involved disciplinary actions connected to breach of company policy and not a lockout.
      • Evidence showed that on the morning of January 22, 1993, the pre-election conference participants had not uniformly reported for work, but a subsequent group did the next day.
    • The Strike and Immediate Aftermath
      • On January 25, 1993, workers attempted to re-enter the premises but were prevented from doing so. Their co-workers, in response, sought an audience with the company’s President and General Manager with no avail.
      • Over 200 workers staged a picket, barricading the company gates and trapping some workers inside, which disrupted normal operations.
      • On January 26, 1993, approximately 700 non-striking workers were prevented from reporting to work due to the ongoing disturbance.
      • On January 27, 1993, a memorandum of agreement was forged between NFL and PERMEX representatives wherein workers were required to explain their participation in the strike; most refused, leading to preventive suspension effective February 13, 1993.
    • Subsequent Procedures and Additional Strike Actions
      • NFL filed a Notice of Strike on January 29, 1993, and when contested on February 5, 1993, they refil a new Notice alleging discrimination, coercion, union busting, blacklisting, intimidation, and dismissal of union officials.
      • On February 3, 1993, PERMEX instituted Case No. RAB 09-02-00062-93 to declare the January strike illegal.
      • From February 11 until March 29, 1993, further strike actions occurred – workers barricaded gates, tied them with ropes and chains, cut the company fence, and orchestrated acts of coercion and intimidation that hampered company operations.
    • Government Intervention and Resolution Steps
      • On March 11, 1993, the Secretary of Labor assumed jurisdiction over the dispute by way of NFL’s petition and issued a Return-to-Work Order.
      • Despite attempts by PNP personnel to ensure compliance, workers continued striking until March 29, 1993 when they finally lifted the picket lines.
    • NLRC’s Decision
      • The Labor Arbiters and subsequently the NLRC (Fifth Division) rendered a decision declaring the strike illegal, dismissing the unfair labor practice case, upholding the dismissal of the 141 workers, and awarding monetary damages (with PERMEX obtaining compensatory damages of P300,000.00).

Issues:

  • Allegation of Grave Abuse of Discretion by the NLRC
    • Whether the NLRC erred in disregarding affidavits and evidence submitted by NFL.
    • Whether the NLRC failed to conduct an open and formal hearing that could have clarified the disputed facts.
  • Procedural Compliance in the Declaration of the Strike
    • Whether NFL complied with the mandatory procedural requisites as provided under the Labor Code (i.e., filing of a notice of strike, holding of a secret-ballot strike vote, observance of cooling-off periods, and submission of appropriate reporting to the NCMB).
    • Whether the alleged “good faith” belief of NFL that PERMEX was instituting unfair labor practices could excuse the noncompliance with established procedural requirements.
  • Validity of the Dismissal of the 141 Workers
    • Whether the dismissal was solely based on a prima facie case of alleged illegal acts during the strike or on their failure to comply with the Return-to-Work Order issued by the Secretary of Labor.
    • Whether due process was observed in dismissing these employees given the disciplinary proceedings and administrative reports relied upon by the NLRC.
  • Assessment of Damage Claims
    • Whether the evidence submitted by PERMEX, including company certifications regarding spoiled products and damages to operations, was sufficient to justify the award of damages.
    • Whether the quantification of damages (moral, exemplary, and compensatory) was supported by concrete evidence or amounted to mere speculation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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