Title
Rizal-Memorial Colleges Faculty Union vs. National Labor Relations Commission
Case
G.R. No. 59012-13
Decision Date
Oct 12, 1989
The school administration was found to have committed unfair labor practices, leading to the reinstatement of faculty members and the payment of backwages.
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Case Digest (G.R. No. 59012-13)

Facts:

  • The case involves Rizal-Memorial Colleges Faculty Union-Davao Workers Union (RMCFU-DWU) and individual petitioners, including Neny Arguna and Helen Basug, against the National Labor Relations Commission (NLRC), Leopoldo Abellera, and Rizal Memorial Colleges (RMC).
  • The dispute began in 1970 when RMCFU accused RMC and Abellera of unfair labor practices, particularly interference with workers' rights to organize.
  • On January 15, 1970, RMCFU's president requested direct recognition and collective bargaining from RMC's board of trustees.
  • RMC's president, Abellera, acknowledged the request but noted a competing request from the Rizal Memorial Colleges Faculty League (RMCFL).
  • RMCFU filed a petition for direct certification as the exclusive bargaining representative, claiming a majority among faculty members.
  • A strike was staged by RMCFU on March 17, 1970, leading to an unfair labor practice complaint against Abellera for allegedly dominating RMCFL to undermine RMCFU.
  • Following a return-to-work agreement that Abellera refused to sign, another unfair labor practice case was filed on August 1, 1970, citing refusal to recognize RMCFU and discrimination against its members.
  • The cases were transferred to the NLRC after the abolition of the Court of Industrial Relations.
  • On December 5, 1978, the Assistant Regional Director found RMC and Abellera guilty of unfair labor practices for refusing to renew contracts of certain teachers due to union activities.
  • The NLRC later modified this decision, absolving RMC and Abellera, prompting the petitioners to seek a reversal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that RMC and Abellera committed unfair labor practices by refusing to recognize and bargain with RMCFU.
  • The Court found the non-renewals of the teaching contracts unjustified and constitutive of unfair labor practices.
  • The petitioners were orde...(Unlock)

Ratio:

  • The Supreme Court emphasized that the refusal to renew contracts was based on union activities, constituting unwarranted interference with the right to self-...continue reading

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