G.R. No. 176085 - Robosa vs. National Labor Relations Commission

Petitioners: Federico S. Robosa, Rolando E. Pandy, Noel D. Roxas, Alexander Angeles, Veronica Gutierrez, Fernando Embat, Nanette H. Pinto, rank-and-file employees and officers/members of CTMI Employees Union-DFA.
Respondents: Chemo-Technische Manufacturing, Inc. (CTMI), its responsible officials led by Franklin R. de Luzuriaga, and Procter & Gamble Philippines, Inc. (P&GPI).

The petitioners were employees of CTMI, a manufacturer and distributor of aWellaa products.
P&GPI acquired all interests and goodwill of CTMI during the pendency of the labor dispute.
In early 1991, the union filed a petition for certification election at CTMI, which was granted by the DOLE-NCR on June 10, 1991.
A consent election held on July 5, 1991, resulted in union’s failure to be certified as exclusive bargaining agent.
On July 15, 1991, CTMI issued a memorandum demobilizing all sales territories and grounding sales representatives, requiring return and sale of company vehicles, and reallocating delivery responsibilities. Another memorandum was issued informing changes in the Salon Business Group’s selling operations.
The union claimed these actions were union-busting unfair labor practices and requested withdrawal and deferment of the orders, which CTMI ignored.
On July 23, 1991, a notice of termination was issued to sales drivers due to abolition of their positions.
On August 1, 1991, the union and affected members filed complaints for illegal dismissal and unfair labor practice and moved for preliminary injunction or TRO.

Labor arbiter denied motion for stay order on grounds the issues could be addressed during trial.
Petition for a preliminary injunction and/or TRO was filed with NLRC on August 16, 1991.
NLRC issued TRO on August 23, 1991, ordering respondents to cease and desist from dismissals and grounding of sales personnel, restore status quo ante prior to union formation and conduct of consent election.
Respondents allegedly did not comply, moved to dissolve TRO and opposed preliminary injunction.
On September 12, 1991, NLRC upgraded TRO to writ of preliminary injunction.
Respondents’ motion for reconsideration denied; contempt proceedings initiated against responsible CTMI officers for non-compliance.
Respondents filed petition for certiorari and prohibition before the Supreme Court, which was dismissed as premature.
Despite this, respondents allegedly defied NLRC orders resulting in the loss of petitioners’ employment.
On October 31, 2000, NLRC dismissed the contempt charges and ordered hearing on merits.
Petitioners moved for reconsideration but failed; then elevated the issue to Court of Appeals (CA).

CA ruled that the dismissal of contempt charges by NLRC was not subject to appellate review as it was akin to acquittal in a criminal case and dismissed the petition on February 24, 2006.
CA denied the motion for reconsideration filed by petitioners on December 14, 2006.

Petitioners filed a Rule 45 petition to reverse the CA resolutions, charging grave abuse of discretion by the NLRC in dismissing contempt charges despite overwhelming evidence of respondents’ non-compliance with orders.
Claims included failure to strictly observe status quo order, failure to reinstate dismissed petitioners, and non-payment of lost wages and benefits.
Petitioners argued that the factual circumstances require application of the Labor Code and that the dismissal of contempt charges is reviewable.
Respondents denied charges, argued NLRC had no jurisdiction over indirect contempt as per Rules of Court, and cited procedural defects and forum shopping.
P&GPI sought to be dropped as party-respondent claiming it was not part of contempt proceedings and contending that the case against it was improper.

Whether the NLRC has the power and jurisdiction to hold parties in contempt, including indirect contempt.
Whether the dismissal of contempt charges by the NLRC is appealable or reviewable by the Court of Appeals or Supreme Court.
Whether the NLRC committed grave abuse of discretion in dismissing the contempt charges against respondents for alleged non-compliance with injunction, TRO, and status quo ante orders.