Case Digest (G.R. No. 109281)
Facts:
Philippine Telegraph and Telephone Corporation (PT&T), Jose Luis Santiago, Epitacio R. Marquez, Jovencio V. Trinidad and Francisco Maglasang, Jr. v. National Labor Relations Commission (NLRC), Associated Labor Union (ALU), Osialito Tiglao, et al., G.R. No. 109281, December 07, 1995, Supreme Court Third Division, Feliciano, J., writing for the Court.Petitioners are PT&T and several of its managers; respondents are the NLRC, the union Associated Labor Union (ALU), and twelve union officers and members (led by Osialito Tiglao, Jr.). The NLRC issued a Resolution dated 29 May 1992 and an Order dated 8 March 1993 directing reinstatement of the twelve private respondents with backwages limited to three years.
The factual background began with certification/run-off elections on 15 November 1986 in which PASAP defeated ALU overall, but ALU scored strongly at PT&T’s Antonino Branch largely through the efforts of ALU Vice‑President Osialito Tiglao, Jr. Management issued two transfer directives moving Tiglao from Antonino Branch Radio Room to the Pasig Nodal Station and later to the Caloocan Nodal Station; ALU protested the transfers but management did not act on the protest.
On 23 February 1987 ALU filed a notice of strike with the Bureau of Labor Relations alleging unfair labor practices; the dispute was certified to the NLRC as NLRC Certified Case No. 0475. On 30 March 1987 PT&T dismissed Tiglao for refusing to comply with the transfer directives; Tiglao filed a complaint for illegal dismissal with the NLRC. A broader wave of labor stoppages occurred in May 1987: on 13 May 1987 PT&T and United Management employees staged a strike, and ALU members struck at PT&T offices in Manila, Davao, Legaspi and Cebu. Several ALU officers and members (the other private respondents) were later separated by PT&T for alleged participation in what PT&T characterized as illegal strikes; they also filed illegal dismissal complaints. The cases were consolidated with NLRC Certified Case No. 0475.
Meanwhile, on 6 June 1987 PT&T filed its own complaint for illegal strike before the NLRC (Arbitration Branch Manila, Case No. 00-06-02046-87). On 22 June 1987 Labor Arbiter Pacita del Rosario, acting on PT&T’s Urgent Motion to Withdraw and/or Consolidate, dismissed PT&T’s illegal strike complaint with prejudice. PT&T did not obtain modification of that dismissal. PT&T later filed consolidated position papers and documentary evidence (including a Consolidated Position Paper dated 29 July 1988) asserting the May 1987 strikes were illegal and defending its separations.
The NLRC resolved the consolidated illegal dismissal cases in a Resolution dated 29 May 1992, ordering reinstatement of the twelve private respondents without loss of seniority and with backwages limited to three years; its denial of a motion for reconsideration followed in an Order dated 6 July 1992 (the rollo also reflects an NLRC Order dated 8 March 1993). Petitioners brought this petition for certiorari, prohibition and mandamus (with p...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion amounting to lack or excess of jurisdiction by refusing to consolidate PT&T’s illegal strike case with the illegal dismissal cases and by denying petitioners’ request for further hearing?
- Did the NLRC err in finding that the dismissal of the private respondents was without just cause?
- Did the NLRC err in ordering reinstatement with backwages (limited to three years) instead o...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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