Facts:

The case involves the petitioners, Samahang Manggagawa ng Rizal Park and Domingo Enriquez, who were employees of the National Park Development Committee (NPDC), a government agency. The events leading to the case began in 1972, shortly after the declaration of martial law in the Philippines. The NPDC, under the leadership of Imelda Marcos and Teodoro F. Valencia, dismissed the petitioners on the grounds that their continued employment was "not compatible with the rules of the New Society." This dismissal occurred after the petitioners proposed negotiations for a collective bargaining agreement, which the NPDC ignored. Following the proposal, the union filed a notice of strike on September 6, 1972, citing management's refusal to bargain collectively and discrimination against union members. The NPDC did not send a representative to the scheduled conference, and shortly thereafter, the petitioners were dismissed, with Corazon Alparicio being terminated on Septembe...

Facts:

Background of the Case

• The petitioners, employees of the National Park Development Committee (NPDC), were dismissed in 1972 on the grounds that their continued employment was "not compatible with the rules of the New Society." This occurred shortly after the imposition of martial law in the Philippines.
• The NPDC was under the chairmanship of Imelda Marcos and the vice-chairmanship of Teodoro F. Valencia at the time.

Union Activities and Dismissals

• In August 1972, the petitioner union proposed negotiations for a collective bargaining agreement, but the proposal was ignored by the NPDC.
• The union filed a notice of strike on September 6, 1972, citing refusal to bargain collectively, refusal to recognize the union, and discrimination against union members.
• A conciliation conference scheduled by the Bureau of Labor Relations could not proceed because the NPDC failed to send a representative.
• On September 16, 1972, petitioner Corazon Alparicio was dismissed, followed by the dismissal of other petitioners on October 3 and 4, 1972. The dismissals were justified with the same vague reason: incompatibility with the rules of the New Society.

Legal Proceedings

• The petitioners filed a complaint with the Department of Labor, but the Labor Arbiter dismissed the case, ruling that Presidential Decree No. 21 (P.D. No. 21), which provided for the jurisdiction of the National Labor Relations Commission (NLRC), was not applicable since the dismissals occurred before its effectivity.
• The case was appealed to the NLRC, but the appeal was delayed due to the burning of the NLRC building on December 13, 1983, which resulted in the loss of case records.
• On June 29, 1990, the NLRC upheld the dismissals, stating that the charge of unfair labor practice was not sufficiently proven.

Jurisdictional Issues

• The NLRC assumed jurisdiction over the case, but subsequent rulings by the Supreme Court clarified that the NPDC is a government agency whose employees are covered by civil service rules, not the Labor Code.
• Despite this jurisdictional issue, the Supreme Court decided to resolve the case on its merits due to its long pendency and the availability of all necessary evidence.

Issue:

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Ruling:

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Ratio:

1. Burden of Proof in Dismissal Cases: The employer must prove that a dismissal is for just cause. The NPDC failed to meet this burden, as the reason given for the dismissals was vague and unsupported by evidence.
2. Due Process in Termination: Employees must be informed of the charges against them and given an opportunity to defend themselves. The NPDC's dismissals violated this principle.
3. Jurisdiction Over Government Employees: Employees of government agencies like the NPDC are covered by civil service rules, not the Labor Code. However, the Court decided to resolve the case on its merits due to its long pendency and the availability of evidence.
4. Reinstatement and Back Wages: The Court ordered the reinstatement of the petitioners and awarded them five years of back salaries as a remedy for their unjust dismissal.