G.R. No. L-23867 - Pagtakhan vs. Court of Industrial Relations

On December 10, 1962, an acting prosecutor of the Court of Industrial Relations (CIR) filed a complaint on behalf of some 43 employees of La Perla Cigar and Cigarette Factory, Inc. (later identified as complainants or petitioners).
The complaint charged the factory and its manager, Lorenzo Lim, with engaging in unfair labor practices related to discriminatory treatment of employees, particularly after their affiliation with the union (FOITAF).

Respondents (the factory and Lorenzo Lim) filed their answer on January 7, 1963, admitting and denying certain allegations, setting up special defenses, and praying for dismissal of the complaint.
The issues in the case were formally joined, and the case was assigned to a trial judge (Justice Jose Bautista) to hear the merits.

Complainants presented their testimonial and documentary evidence during the trial phase.
On February 21, 1964, following the presentation of the complainants’ evidence, the respondents filed a motion to dismiss on two grounds:

The trial judge denied the motion to dismiss on March 16, 1964 and set further hearings for March 23 and April 1, 1964.

At the March 23, 1964 hearing, the respondents and their counsel failed to appear.
Complainants indicated that if the respondents again failed to appear on April 1, 1964, they would move for submission of the case based on the evidence already presented.
Despite a motion for reconsideration filed by the respondents on March 24, 1964 (and supplemented by subsequent filings on April 2, 1964), the respondents did not appear at the April 1, 1964 hearing, prompting complainants to move for submission.

On May 20, 1964, the trial judge issued an order finding the respondents guilty of unfair labor practices, ordering:

The reinstatement of the complainants to their former positions without loss of seniority and privileges.
Payment of backwages from April 1959 (when the branch reopened) until actual reinstatement.

Respondents then filed a motion for reconsideration of the May 20, 1964 order, supported by a memorandum dated June 9, 1964, and opposed by complainants who argued the motion was unverified and intended solely for delay.
The motion for reconsideration was later heard on oral argument before the CIR en banc on September 24, 1964.

It set aside the trial judge’s May 20, 1964 order.
It ordered the return of the case to the trial court for further proceedings, specifically for the reception of respondents’ evidence.

The resolution also addressed another motion for reconsideration (filed on March 24, 1964) but declined to resolve it, stating that respondents had been given their day in court.
Complainants later moved for reconsideration of the CIR en banc’s resolution, but the motion was denied on November 5, 1964.
Ultimately, petitioners filed a petition for certiorari to review the en banc resolution, raising the central issue regarding suspension of proceedings during a motion for reconsideration.

Whether the proceedings before a trial judge of the CIR should be considered automatically suspended upon the filing of a motion for reconsideration of an interlocutory order.
Whether the filing of such a motion effectively elevates the case to the CIR en banc, thereby preventing the trial judge from proceeding with the hearing.

Whether the denial of a motion to dismiss (a demurrer to evidence) by a trial judge, being interlocutory in nature, can be subject to appeal or review via a motion for reconsideration.
How allowing such appeals could potentially lead to piecemeal and delay tactics that frustrate the speedy disposition of cases.

Whether the trial judge’s decision to proceed with the hearing and to ultimately rule on the case based solely on the complainants’ evidence was proper, despite the pending motion for reconsideration filed by the respondents.
Whether the respondents’ absence at scheduled hearings, and their attempt to use motions for reconsideration as a delaying mechanism, justified a suspension of proceedings.