Case Digest (G.R. No. 140992)
Facts:
Samahang Manggagawa sa Sulpicio Lines, Inc. NAFLU v. Sulpicio Lines, Inc., G.R. No. 140992, March 25, 2004, Supreme Court Third Division, Sandoval‑Gutierrez, J., writing for the Court.Petitioners are Samahang Manggagawa sa Sulpicio Lines, Inc. NAFLU (the union) and several named union officers and members; respondent is Sulpicio Lines, Inc. The parties executed a five‑year collective bargaining agreement (CBA) effective October 17, 1990 to October 16, 1995; the negotiated economic provisions covered October 17, 1993 to October 16, 1995. Negotiations over the economic provisions reached an impasse, and on March 1, 1994 the union filed a notice of strike with the NCMB (NCMB‑NCR‑NS‑03‑118‑94).
Respondent asked the Labor Secretary to assume jurisdiction; on March 23, 1994 then‑Secretary Nieves R. Confesor issued an order assuming jurisdiction under Article 263(g) of the Labor Code and enjoined any strike or lockout. On May 20, 1994 the union filed a second notice of strike (NCMB NCR‑05‑261‑94) alleging assorted unfair labor practices by respondent. That same morning about 167 officers and members did not report for work and assembled at Pier 12, North Harbor; the Secretary issued another order on May 20 directing return to work and certifying the dispute to the NLRC for compulsory arbitration (NLRC Case No. CC‑0083‑94). Respondent filed a separate complaint for illegal strike/clearance for termination with the NLRC (NLRC NCR Case No. 00‑05‑04705‑94).
On September 29, 1995 the NLRC resolved that the May 20, 1994 refusal to work was an illegal strike, held that the union failed to comply with the procedural requirements of Articles 263(c) and (f), dismissed the union’s complaint against respondent, and declared specified union officers to have lost their employment status and subject to termination. The NLRC denied reconsideration on January 15, 1996. Petitioners filed a certiorari petition with the Supreme Court on March 19, 1996 which, following St. Martins Funeral Home v. NLRC, was referred to the Court of Appeals.
The Court of Appeals, in a decision dated May 28, 1999 (denied reconsideration November 25, 1999), affirmed the NLRC: (1) the NLRC had jurisdiction to resolve the legality of the strike; (2) the May 20, 1994 stoppage was an illegal strike; (3) even if unfair labor practices were proven, petitioner...(Subscriber-Only)
Issues:
- Did the NLRC have jurisdiction to rule on the legality of the May 20, 1994 work stoppage?
- Was the May 20, 1994 work stoppage by petitioners’ officers and members an illegal strike for failure to comply with Article 263(c) and (f) and related DOLE implementing guidelines?
- Were the union officers properly declared to have lost their employment status for participating in the illegal strike unde...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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