G.R. No. L-22273 - Pagkakaisang Itinataguyod ng mga Manggagawa sa Ang Tibay vs. Ang Tibay, Inc.

Petitioners: Pagkakaisang Itinataguyod Ng Mga Manggagawa sa Ang Tibay (the Union) and several of its members.
Respondents: Ang Tibay, Incorporated (the Company), its Assistant General Manager, Prudencio Teodoro, and the Court of Industrial Relations.
The petition was filed to review a decision in the Court of Industrial Relations (CIR Case No. 1512-ULP) which:

Declared illegal the strike staged by the petitioners on November 14, 1957.
Dismissed the complaint for unfair labor practices filed by the Union against the Company and its officials.

On June 26, 1956, the complainant union sent a letter to the Company requesting the renewal of the collective bargaining agreement (CBA) of August 6, 1955 and the enforcement of its terms, including a P0.05 increase per hour for regular hourly workers.
The Company complied with the increase for most workers except for Jesus Guevarra, a union member who was not fully paid.

On or about September 6, 1957, the union again addressed the non-payment issue, resulting in partial remediation on September 12, 1957; however, Jesus Guevarra was dismissed on the same day.
The union also highlighted the failure of the Company to grant vacation leave benefits as provided in the CBA for several other workers, leading to operational cessation in the slipper department on March 16, 1957, which affected these workers (except Armando Jacinto).
Additionally, Asuncion Ablaza was summarily dismissed around June 10, 1957 allegedly due to her active union membership and secretarial duties.

On September 6, 1957, the union made a final settlement proposal addressing the pending issues.
The Company responded on September 12, 1957, leading to the filing of a notice of strike by the union on September 20, 1957.
The strike was eventually staged on November 14, 1957 after the parties failed to come to a satisfactory agreement, despite previous proposals for reinstatement of dismissed employees and payment of separation benefits.

On November 15, 1957, the union and the Company reached an agreement to settle their differences and agree on the readmission of the strikers.
When the strikers reported for work on November 18, 1957, the Company conditionally refused their readmission unless they apologized for the strike and admitted its wrongful nature—a condition which was not accepted by the strikers.

Some of the workers were hired by an independent contractor, not directly by the Company.
The dismissals of Jesus Guevarra and Asuncion Ablaza were justified and not linked to unlawful union activities.

The dismissals and failure to grant certain benefits were justified and not motivated by union activities.
The strike was declared illegal, as it occurred when the parties were already in a near-settlement state and was in violation of the CBA by not following the prescribed grievance machinery.
The conditions imposed on the strikers for readmission were not discriminatory based on union membership.

The Industrial Court dismissed the unfair labor practices complaint and held that it had no jurisdiction to order the reinstatement of the strikers.

The union, unsatisfied with the dismissal, appealed the Industrial Court’s decision.
In the appeal, petitioners shifted one of the theories by arguing that the strike had been precipitated by the Company’s breach of the CBA (specifically the violation of the provision against summary dismissal).
The court noted that the original action was strictly for unfair labor practices under Section 4(a) of Republic Act No. 875, not a breach of the CBA per se, which belongs to the arena of ordinary contractual disputes.

Whether the Industrial Court possessed jurisdiction to order the reinstatement of the strikers given the nature of the complaint.
Whether matters pertaining to the breach of a collective bargaining agreement should be redressed in the Industrial Court or in the regular courts.

Whether the dismissal of Jesus Guevarra and Asuncion Ablaza was justified and properly executed without being influenced by their union membership.
Whether the failure to grant vacation leave and sick leave to the extra slipper-makers was justified under the circumstances.

Whether the strike staged on November 14, 1957 was illegal given that there was an existing near-agreement between the parties.
Whether the strike was in contravention of the terms of the collective bargaining agreement due to the disregard for the prescribed grievance machinery.

Whether the Company’s demand that strikers must apologize for the strike and pledge not to commit acts against union members was discriminative and constituted an unfair labor practice under Republic Act No. 875.
Whether such condition was an act of self-preservation aimed at maintaining discipline and order in the workplace.