G.R. No. L-20303 - Republic Savings Bank vs. Court of Industrial Relations

The petitioner, Republic Savings Bank (now Republic Bank), employed eight respondents: Rosendo T. Resuello, Benjamin Jara, Florencio Allasas, Domingo B. Jola, Diosdado S. Mendiola, Teodoro de la Cruz, Narciso Macaraeg, and Mauro A. Rovillos.
On July 12, 1958, the Bank discharged respondent Jola, and on July 18, 1958, it discharged the remaining employees.
The discharges were based on the respondents having written and published what the Bank described as a “patently ribelous letter” intended to damage the reputation of the bank and its management.

The letter, dated July 9, 1958, was addressed to the bank president, Mr. Ramon Racelis, demanding his resignation.
The letter alleged several charges against the president, including:

Immorality – accusing him of tolerating and engaging in misconduct (e.g., illicit relations with employees such as Miss Edita Castro).
Nepotism – alleging favoritism in employing and promoting relatives (e.g., Honorio Ravida, Bienvenido Ravida, Antonio Racelis, Jesus Antonio, and Argentina Racelis) over more competent employees.
Discriminatory and biased promotion practices – with specific charges related to the preferential treatment in promotions and even the transfer of employees abroad for training under questionable circumstances.
Management irregularities – citing financial discrepancies and misconduct in various branches, including embezzlement, unauthorized transactions, and acceptance of bribe moneys by personnel.

The letter-charge was signed by various union representatives who, while acting in their “individual” capacity, were seen as conveying collective grievances regarding management practices.

On September 15, 1958, a complaint was filed by prosecutor A. Tirona in the Court of Industrial Relations (CIR).
The complaint alleged that the Bank’s actions violated Section 4(a)(5) of the Industrial Peace Act, which prohibits dismissal or discrimination against employees for filing charges or giving testimony under the Act.
The Bank moved to dismiss the complaint, contending that the dismissals were for cause—specifically, for libel rather than union or collective activities.

The CIR had previously ruled in another case that Section 4(a)(5) covers any charge filed against the employer, irrespective of whether the action is strictly “union” related.
The dispute was later revisited by this Court in light of the Royal Interocean Lines decision, where it was held that for a dismissal to fall under an unfair labor practice, the charge must relate to the employee’s right to self-organization.
The Court noted that even if the respondents acted in their individual capacity, their actions were part of a concerted effort and pertained to issues of collective bargaining, grievance redressal, and employee self-organization.

The Bank maintained that the respondents’ actions amounted to libel against the president and the institution, justifying disciplinary dismissal.
It argued that the letter-charge was an “individual” act and not a union-driven or collective bargaining exercise.
The Bank further contended that it retained its right to discipline employees for cause, separate from any protections under the Industrial Peace Act.

The CIR and subsequent analysis noted that even individual actions may constitute a concerted activity when they involve airing grievances related to labor-management relations.
The letter-charge was understood as an expression of discontent with managerial practices (immorality, nepotism, favoritism) that directly affected working conditions and the morale of the employees.
The Act’s protection was thereby extended to cover such activities as part of the right to self-organization and collective bargaining.

Whether the dismissal of the eight employees for writing and distributing the letter-charge constituted an unfair labor practice under the Industrial Peace Act.

Was the discharge effectively a punitive action for engaging in a protected concerted activity aimed at addressing grievances relating to management practices?
Does the fact that the respondents acted “individually” preclude them from the protections afforded by the Act regarding collective bargaining and self-organization?

Whether the bank’s defense invoking disciplinary measures for libel was a legitimate exercise of its right to discipline, or an improper retaliatory act infringing on the employees’ rights.

To what extent can a dismissal for cause (libel) be justified if it overlaps with a violation of employees’ rights to raise collective grievances?
How should the court balance the employer’s right to maintain discipline and the statutory protection of employee grievance procedures?