G.R. No. 140992 - Samahang Manggagawa sa Sulpicio Lines, Inc. vs. Sulpicio Lines, Inc.

Sulpicio Lines, Inc. (respondent) and Samahang Manggagawa sa Sulpicio Lines, Inc. a NAFLU (petitioner) entered into a CBA with a five-year term (from October 17, 1990 to October 16, 1995).
After three years into the agreement (on December 15, 1993), the parties began negotiations on the economic provisions; however, these negotiations reached an impasse.

On March 1, 1994, the petitioner filed a notice of strike with the National Conciliation and Mediation Board (NCMB), National Capital Region, due to the deadlock in collective bargaining (docketed as NCMB-NCR-NS-03-118-94).
On March 21, 1994, respondent filed a petition with the Office of the Secretary, Department of Labor and Employment, requesting that the Labor Secretary assume jurisdiction over the dispute.
Former Labor Secretary Nieves R. Confesor, on March 23, 1994, issued an order assuming jurisdiction over the dispute under Article 263 (g) of the Labor Code, which also enjoined any strike or lockout and directed both parties to cease game-escalating acts.

On May 20, 1994, the petitioner filed a second notice of strike with the NCMB (docketed as NCMB NCR-05-261-94), alleging that the respondent committed unfair labor practices amounting to union busting.
In response to alleged unfair labor practices, the union conducted a strike vote, and at about 9:30 in the morning of May 20, 1994, 167 union rank-and-file employees, officers, and members collectively did not report for work.
As a remedial measure, former Labor Secretary Confesor issued an order on May 20, 1994, directing the striking employees to return to work and certifying the dispute to the National Labor Relations Commission (NLRC) for compulsory arbitration (docketed as NLRC Case No. CC-0083-94).
Meanwhile, respondent filed a complaint with the NLRC for illegal strike/clearance for termination (docketed as NLRC NCR Case No. 00-05-04705-94).

On September 29, 1995, the NLRC issued a resolution declaring the strike illegal, noting that the petitioner had failed to observe the procedural requirements, specifically the mandated filing of a notice and the proper strike vote.
The resolution further declared that the dismissal of the union officers who knowingly participated in what was deemed an illegal strike was justified, and it dismissed the union’s complaint against the company.
The petitioner’s motion for reconsideration before the NLRC was denied on January 15, 1996.
On March 19, 1996, the petitioner elevated the issue to the Supreme Court via a petition for certiorari challenging the NLRC Resolutions.
Based on earlier rulings and the doctrine of the hierarchy of courts, the case was referred to the Court of Appeals, which on May 28, 1999, rendered a decision affirming the NLRC’s resolution, and upon a subsequent motion for reconsideration by the petitioner, the Court of Appeals denied relief in its November 25, 1999 resolution.

The dispute centers on whether the actions of the union on May 20, 1994—specifically, the one-day work stoppage by its officers and members—constituted an illegal strike.
The case involves a scrutiny of compliance with Articles 263 and 264 of the Labor Code, which set forth the mandatory requirements for a legal strike, including the proper notice period and the conduct of a secret ballot strike vote with appropriate submission of the results to the Department of Labor and Employment.
The petitioner alleged that the employer engaged in unfair labor practices (e.g., illegal mass dismissal, wage discrimination, coercion, and union busting), though the records ultimately did not sustain such evidence.

Whether the one-day work stoppage by the union's officers and members on May 20, 1994 constitutes an illegal strike.
Whether the dismissal of the union’s officers who participated in the said work stoppage is justified under Article 264 (a) of the Labor Code.
Whether the NLRC and, by extension, the Court of Appeals properly exercised jurisdiction over the labor dispute, including decisions on the legality of the strike.
Whether the alleged unfair labor practices committed by the respondent, if proven, would have justified the union's actions even if procedural requirements were not fulfilled.