G.R. No. L-25094 - Pan American World Airways, Inc. vs. Pan American Employees Association

Petitioner: Pan American World Airways, Inc.
Respondent: Pan American Employees Association, represented in proceedings before the Court of Industrial Relations.
The dispute arises from a labor strike and subsequent return-to-work order affecting both union rank-and-file members and five designated union officers.

On August 25, 1965, the respondent union filed a notice of strike with the Department of Labor.
On August 28, 1965, the union declared and maintained the strike against the petitioner.
On September 17, 1965, the President of the Philippines certified the strike as an industrial dispute affecting the national interest, thus invoking compulsory arbitration procedures.
Several conferences were held between the parties and the Court of Industrial Relations (specifically on September 20, 21, 23, 24, and 25, 1965) under the supervision of Associate Judge Amando C. Bugayong.

The union maintained that all its members, including its officers, should resume work together.
The demand was rooted in the collective bargaining framework which empowers the union to act as a unit.

While the petitioner agreed that workers should return to work, it contended that the five union officers should be excluded from the return-to-work order.
The petitioner argued that these officers had led an illegal strike in violation of the no-strike clause in an existing collective bargaining agreement.
It asserted that allowing these officers to resume work would strip them of any incentive and motivation by effectively nullifying the ground for their dismissal, potentially leading to grave injury to the company.
As a remedial measure, petitioner even offered to deposit their salaries during the period of exclusion, coupled with a promise not to require a refund should their employment rights later be terminated.

On September 28, 1965, Judge Bugayong of the Court of Industrial Relations issued an order requiring the petitioner to accept the return of the five union officers pending the final resolution of the dispute.
A motion for reconsideration of this order was filed by the petitioner but was subsequently denied on October 8, 1965.

Petitioner challenged the Court of Industrial Relations for its failure to exclude the five union officers from the return-to-work order.
The argument was based on the claim that such exclusion was necessary due to the alleged illegality of the strike and the consequent risk of irreparable injury to the petitioner.
The petitioner contended that the court’s failure amounted to a grave abuse of discretion warranting intervention by a higher court.

Whether the Court of Industrial Relations committed a grave abuse of discretion by refusing the petitioner's plea to exclude the five union officers from the return-to-work order.
Whether the petitioner’s unorthodox demand to exclude the union officers—on grounds tied to an illegal strike and potential operational harm—undermines the established authority of the Court of Industrial Relations under compulsory arbitration.
Whether restricting the union officers’ right to return to work would violate the principles of collective bargaining and the constitutional right to freedom of association.