G.R. No. 170830 - Phimco Industries, Inc. vs. Phimco Industries Labor Association

Petitioner: PHIMCO Industries, Inc., a corporation engaged in match production, located at Phimco Compound, Felix Manalo St., Sta. Ana, Manila.
Respondents: Phimco Industries Labor Association (PILA) and its individually named union officers and members representing the daily-paid workers of PHIMCO.

As the collective bargaining agreement neared expiration on December 31, 1994, negotiations between PHIMCO and PILA resulted in a deadlock—primarily over economic issues such as salary increases and benefits.
In response to the deadlock, PILA filed a Notice of Strike with the National Conciliation and Mediation Board (NCMB) on March 9, 1995.
A strike vote was conducted on March 16, 1995, resulting in a majority favoring the strike, with the vote results submitted to the NCMB on March 17, 1995.
The actual strike was staged on April 21, 1995, following the mandated procedural requirements.

On May 3, 1995, PHIMCO filed a petition for a preliminary injunction and temporary restraining order (TRO) with the National Labor Relations Commission (NLRC) to stop the strikers from forcibly blocking entry and exit of non-striking employees.
The NLRC issued an ex-parte TRO on May 15, 1995, effective until June 5, 1995.
On June 23, 1995, PHIMCO sent a letter to 36 union members directing them to explain within 24 hours why they should not be dismissed for allegedly committing illegal acts during the strike.
PHIMCO dismissed the 36 union members on June 26, 1995.

On July 6, 1995, PILA filed a complaint for unfair labor practice and illegal dismissal with the NLRC.
In a separate illegal strike case, PHIMCO filed a petition on August 28, 1995, claiming that the strike obstructed entry and exit, paralyzing company operations.
The two cases—illegal dismissal and illegal strike—were eventually consolidated by the NLRC on August 5, 1999.
On February 20, 2002, the NLRC rendered a decision favoring the union by dismissing PHIMCO’s motion for reconsideration in the strike case and sustaining the illegal dismissal ruling for the union members, while ruling out reinstatement due to damages sustained by the company.
PHIMCO subsequently filed a motion for reconsideration on March 14, 2002, and elevated the case to the Court of Appeals through a petition for certiorari under Rule 65 on April 26, 2002.
The Court of Appeals (CA) dismissed PHIMCO’s petition on February 10, 2004. PHIMCO then elevated the case to the Supreme Court through a petition for review on certiorari.

Whether the strike conducted by PILA was legal despite complying with the mandatory procedural requirements.
Whether the manner in which the picketing was carried out—specifically, by obstructing the ingress to and egress from PHIMCO’s premises—rendered the strike illegal under Article 264(e) of the Labor Code.

Whether the NLRC erred in characterizing the picket as “peaceful and moving” despite evidence of physical obstruction.
Whether the Court of Appeals correctly exercised its limited review under Rule 65 by determining that the NLRC did not commit grave abuse of discretion.

Whether PHIMCO complied with the due process requirements in dismissing union officers and members, specifically the adequacy of notice and the opportunity to be heard as mandated by Articles 264(a) and 277(b) of the Labor Code.

Whether the resulting termination actions, despite being for just cause because of illegal picketing, warranted the imposition of nominal damages due to due process violations.