Case Digest (G.R. No. 39040)
Facts:
Royal Undergarment Corporation of the Philippines v. Court of Industrial Relations, G.R. No. L-39040, June 06, 1990, Supreme Court First Division, Medialdea, J., writing for the Court.Petitioner Royal Undergarment Corporation of the Philippines employed Antonio Cruz as an electrician beginning in 1957. In December 1961 Cruz was elected president of the Royal Undergarment Workers Union (RUWU), which affiliated with the Philippine Transport and General Workers Organization (PTGWO). On December 14, 1961 RUWU-PTGWO, represented by PTGWO’s national secretary and Cruz as RUWU president, presented collective bargaining proposals to petitioner.
On December 15, 1961 petitioner, through its personnel manager, terminated Cruz and his wife (also an employee). RUWU struck in early January 1962. A Return-to-Work Agreement executed January 10, 1962 provided that reinstatement of Cruz and his wife would follow if RUWU-PTGWO prevailed in a consent election; Cruz and his wife were later re-employed, indicating a union victory. A collective bargaining agreement with a grievance procedure was signed March 31, 1962 and used thereafter.
In November 1962 PTGWO urged member unions to join a nationwide strike; Cruz campaigned for participation. On the night of November 28, 1962 Cruz allegedly, while intoxicated, threatened several supervisors inside company premises. The supervisors executed affidavits; petitioner placed Cruz on preventive suspension November 30, 1962 effective December 3, 1962 and after a conference dismissed him December 13, 1962 for intoxication and threats.
Cruz filed an unfair labor practice complaint with the Court of Industrial Relations (CIR). On January 21, 1974 the CIR found petitioner guilty of unfair labor practice, ordered it to cease and desist, reinstated Cruz and awarded backwages through November 17, 1969. Petitioner sought review by the Supreme Court via a petition for review on certiorari, assigning as errors (1) alleged grave misapprehension of fact i...(Pro-only)
Issues:
- Did the Court of Industrial Relations commit a grave misapprehension of fact in finding that Cruz’s dismissal was caused by his union activities?
- Was Cruz’s December 13, 1962 dismissal for cause under the Termination Pay Law and justified by management prerogative?
- Should Cruz’s awarded backwages be reduced by the income he earned duri...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)