G.R. No. 259221 - People vs. XXX

The Philippine Marine Radio Officers Association (PHILMAROA) presented a list of demands to various maritime stakeholders, including the Association de Navieros, the Philippine Shipowners’ Association, and the Luzon Stevedoring Company.
The demands included:

On September 25, 1953, the Associacion de Navieros informed PHILMAROA that the petition had been referred to its member companies, notably Compania Maritima and the Philippine Steam Navigation Company (PSNCO).
On October 22, 1953, the Philippine Shipowners’ Association, representing companies such as Madrigal Shipping Company, Visayan Transportation Company, and Bisaya Land Transportation, declined to negotiate directly with PHILMAROA, urging the union to approach its member companies instead.
PHILMAROA, in addition, presented its demands to other relevant parties including Bisaya Land Transportation Company and Royal Steamship Lines on September 26, 1953.

Having received unsatisfactory or non-committal responses from the companies, PHILMAROA issued notice of its intention to strike.

Notices were sent on October 17 and October 24, 1953, to the affected companies and the Chief of the Conciliation Service Division, Department of Labor.

The Association de Navieros and the Philippine Shipowners’ Association stated they lacked authority to bargain collectively and recommended that their member companies be notified.
Following notification, the companies questioned the union’s authority and demanded the submission of the members’ list.

On November 13, 1953, during another conference before the Conciliation Service Division, the parties agreed to grant the respondents a six-day period to address the demands.
Despite this grace period, PHILMAROA declared strikes:

On February 22, 1954, the case was certified to the Court of Industrial Relations pursuant to Section 10 of Republic Act No. 875.
The trial was conducted with Hon. Jose S. Bautista presiding, where the following orders were issued:

The respondent companies were ordered to reinstate the striking radio operators to their former positions.
The decision granted backpay for the period preceding reinstatement only under very specific conditions, while denying other claims such as standardization, vacation leave with pay, and a closed shop agreement.
Specific benefits, like free hospitalization and sick leave with pay, were selectively granted based on evidence and the companies’ ability to pay.

The trial judge’s findings negated any acts amounting to discrimination or improper denial of the union’s claims, holding that the delay in responding to demands was not unreasonable given the number and complexity of the issues raised.

The Philippine Marine Radio Officers’ Association appealed the decision on two major grounds:

The alleged absence of an issue of unfair labor practice that would warrant backpay.
The contention that the respondents’ delay amounted to a refusal to bargain collectively.

Separately, Compania Maritima and other petitioners contended on the interpretation of Section 10 of the Industrial Peace Act, challenging the court’s power to order reinstatement and fix terms, including backpay.
The appeals were considered in two separate cases:

Whether the respondent companies’ delay in responding to the union’s demands constituted an act of unfair labor practice or amounted to a refusal to bargain collectively.

The contention centered on whether such delay could justify the granting of backpay to the striking employees.

Whether the union’s strike was induced by unlawful or unfair practices on the part of the employers and if such conditions justified compensation during the period of the strike.

It was argued that any act amounting to unfair labor practice should entitle the employees to backpay for the days they were absent.

Whether the Court of Industrial Relations had the jurisdiction and power, under Section 10 of the Industrial Peace Act and by extension Commonwealth Act No. 103, to:

Order the reinstatement of striking employees.
Dictate the terms and conditions of employment, including the issue of backpay.
Enforce a decision which might include ordering reinstatement even if replacements had been made during the strike.

Whether the principle of “fair day’s wage for a fair day’s labor” applies in the context of no work being performed during a voluntary strike.