Case Digest (G.R. No. L-31195) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Blooming Mills Employees Organization et al. v. Philippine Blooming Mills Co., Inc. and Court of Industrial Relations (G.R. No. L-31195, June 5, 1973), the petitioner Philippine Blooming Mills Employees Organization (PBMEO), a duly accredited labor union, and eight of its officers decided on March 1, 1969 to lead some 400 employees in a public demonstration on March 4, 1969 at Malacañang, protesting alleged abuses by the Pasig municipal police. Two separate meetings were held on March 3, 1969 between union representatives and company management, wherein management acknowledged the demonstrators’ constitutional rights but warned that day-shift workers who failed to report for work without approved leave would be dismissed for violating the “No-Strike/No-Lockout” clause of the existing collective bargaining agreement (CBA). Despite a cablegram reiterating the union’s request to excuse day-shift participants, the officers proceeded with the demonstration on March 4, r Case Digest (G.R. No. L-31195) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and context
- Philippine Blooming Mills Employees Organization (PBMEO) is a legitimate labor union of Philippine Blooming Mills Co., Inc. employees. Officers include Nicanor Tolentino, Florencio Padrigano, Rufino Roxas, Mariano de Leon, Asencion Paciente, Bonifacio Vacuna, Benjamin Pagcu and Rodulfo Munsod.
- On March 1, 1969, PBMEO decided to stage a mass demonstration at Malacañang on March 4, 1969, protesting alleged abuses by the Pasig police. They informed the Company in advance.
- Company-union meetings before the demonstration
- March 3, 11:00 A.M.: Company representatives (Arthur L. Ang, Atty. Cesareo S. de Leon Jr., department heads) met the union panel. The panel confirmed the demonstration and declined to cancel it, insisting it did not concern the Company.
- Company warned union that first-shift (6 A.M.–2 P.M.) and regular-shift workers who joined the rally without approved leave would be dismissed as engaging in an illegal strike (violation of the CBA “No-Lockout, No-Strike” clause).
- March 3, 5:00 P.M.: A second meeting reiterated the warning; union said it was too late to change plans.
- March 4, 9:50 A.M.: PBMEO adviser sent cablegram reiterating request to excuse day-shift employees for the demonstration.
- Charges, CIR proceedings and appellate steps
- March 4, 1969: Company filed an unfair-labor-practice (ULP) charge with the Court of Industrial Relations (CIR), alleging violation of RA 875 Secs. 4(a)-6, 13, 14 and 15 and the CBA’s no-strike clause by first-shift employees who failed to report for work.
- Petitioners answered (May 9) that the rally was a valid exercise of their constitutional rights, not a strike, and that they gave prior notice.
- September 15, 1969: Associate Judge Joaquin M. Salvador’s order found PBMEO guilty of bargaining in bad faith; union officers were declared to have lost employee status.
- September 29, 1969: Petitioners filed a motion for reconsideration (two days late under CIR rules) and asked ten days to file supporting arguments.
- October 9, 1969: CIR en banc dismissed the motion as pro forma for lateness. Petitioners received notice October 28.
- October 31, 1969: Petitioners filed a petition for relief from the order (alleging excusable negligence by counsel’s clerk).
- November 3, 1969: Petitioners filed a notice of appeal to the Supreme Court.
Issues:
- Whether staging a mass demonstration against police abuses—after prior notice to the employer and without a dispute over employment conditions—constitutes bargaining in bad faith or an illegal strike under the CBA and RA 875.
- Whether the Company’s warnings and the CIR’s dismissal orders deprived petitioners of their constitutional rights and therefore amounted to unfair labor practice.
- Whether the CIR abused its discretion by dismissing petitioners’ motion for reconsideration as pro forma for tardiness, despite the asserted exercise of constitutional rights and equitable considerations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)