Title
National Labor Union, Inc. vs. Philippine Match Factory
Case
G.R. No. 47107
Decision Date
Jun 27, 1940
The court ruled that the labor union's demand for the foreman's dismissal and subsequent general strike were unjustified due to the lack of specific charges.
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Case Digest (G.R. No. 47107)

Facts:

  • The case involves the National Labor Union, Inc. and its members as petitioners against the Philippine Match Factory and the Court of Industrial Relations as respondents.
  • On August 31, 1939, the union chapter at the Philippine Match Company demanded the dismissal of general foreman Pablo Pabalan.
  • The factory manager, Mr. During, requested specific charges against Pabalan for investigation.
  • The union initially failed to provide specific allegations but later outlined four charges.
  • The company's attorneys investigated and found the charges lacked merit, including an alleged assault by Pabalan against an employee named Dineros.
  • While the investigation was ongoing, the union's officers resigned en masse, seemingly to preempt an unfavorable decision and facilitate a general strike.
  • On September 16, 1939, the union declared a general strike, paralyzing operations for fifteen days.
  • The company reported the strike to the Department of Labor, leading to a conference that failed to resolve the dispute.
  • The Secretary of Labor referred the case to the Court of Industrial Relations on September 21, 1939.
  • The petitioners initially objected to the court's jurisdiction but later withdrew their objection.
  • On October 11, 1939, fifteen strikers sought readmission, but the company manager refused.
  • The petitioners filed a motion in the Court of Industrial Relations to compel readmission.
  • On November 6, 1939, the court denied both the petition for Pabalan's dismissal and the petition for the strikers' readmission.

Issue:

  • (Unlock)

Ruling:

  • The Court of Industrial Relations ruled against the petitioners on both issues.
  • The court denied the petition for the dismissal of Pablo Pabalan.
  • The court also deni...(Unlock)

Ratio:

  • The court found the charges against Pabalan to be unsubstantiated and deemed the union's actions leading to the strike unjustified.
  • The court emphasized that the law recognizes the right to strike in a negative sense, providing mechanisms to avoid strikes through lawful means.
  • The creation of the Court of Industrial Relations aimed to prevent strikes by offering a platform for resolving lab...continue reading

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