G.R. No. L-12682 - San Miguel Brewery, Inc. vs. Santos

The petitioners are San Miguel Brewery, Inc. and Col. Jose P. Rueda (its Security Officer).
The respondent is Peter C. Santos, a member (and later, confidential agent) of the SMB Special Police Union, along with the Court of Industrial Relations.
The complaint charged that petitioners committed unfair labor practices by:

Interfering with, restraining, and coercing Santos in the exercise of his right to self-organization;
Harassing and discriminating against him by not appointing him to a permanent security guard position and eventually dismissing him; and
Refusing to reinstate or reappoint him despite the union’s recommendation, especially given that he had assisted in filing charges against the Security Officer, Col. Rueda.

Santos was employed on-and-off as a temporary security guard from December 16, 1952 until February 3, 1955, totaling approximately eight and a half months of service.
His union involvement is evidenced by:

Appointment as confidential agent of the union on April 11, 1954;
Formal membership in the union on October 23, 1954; and
Subsequent recommendation by the union’s board for him to replace permanent guard Carlos Abelardo.

On April 1, 1954 (with a noted correction to August 1, 1954), the union filed charges against Col. Rueda, with Santos gathering materials and information for these charges.
The union simultaneously recommended that vacancies created by union members’ resignation or retirement be filled by applicants endorsed by the union.
On September 26, 1955, the union’s board recommended that Santos take the position vacated by Carlos Abelardo.
Episodes of physical examination are noted:

Santos underwent a physical exam on November 3, 1954, and again on January 27, 1955;
The examinations were ostensibly to determine if he was fit to be made a permanent guard, though later findings of a chronic defect (O.M.P.C. on his left ear) served as a pretext for non-reinstatement.

Col. Rueda and the management denied that the dismissal or non-appointment of Santos was due to his union activities, claiming:

Santos was not even a bona fide member at the relevant times (despite evidence proving otherwise);
The choice of permanent versus temporary appointment was solely at the company’s discretion; and
Any disputes were purely personal and lacked implications for labor relations.

Rueda was aware of Santos’s active union role and his involvement in filing charges against him;
The investigation, including inquiries about firearms possession and repeated physical examinations, was conducted under circumstances suggesting that a physical defect was used as a pretext for dismissal; and
Rueda’s admission that he “gave him bread and butter” implies a personal relationship that, when betrayed by union-related activities, prompted retaliatory actions.

The lower court found that the dismissal of Santos was linked to his union activities and ordered:

His reinstatement to a permanent security guard position (in vacated place of Carlos Abelardo);
Payment of back wages from the date of his dismissal until reinstatement; and
A directive for respondents to cease engaging in similar unfair labor practices.

The petitioners filed an appeal by certiorari on several grounds, alleging errors in:

The handling of the motion for reconsideration;
Findings not supported by substantial evidence;
Non-conformity with earlier Supreme Court precedents; and
Exceeding the court’s jurisdiction by directing a permanent position appointment when Santos had been employed as a temporary guard.

Whether the dismissal of Peter C. Santos was attributable to his union activities rather than any legitimate cause.

Did the actions and investigations by Col. Rueda, including the misuse of medical examinations, constitute a pretext for the dismissal?
Was the union affiliation of Santos improperly used against him in employment decisions?

Whether the Court of Industrial Relations correctly found that unfair labor practices were committed by petitioners in view of the cumulative evidence.

Was sufficient evidence presented to link Santos’s union activities with the adverse employment decisions?
Can personal misunderstandings between Santos and Rueda be distinguished from acts affecting labor relations?

Whether the ordering of reinstatement to a permanent guard position was appropriate given Santos’s prior status as a temporary guard.

Is reinstatement properly interpreted as restoration to the former job position?
Should the remedy extend beyond mere restoration to temporary status under the circumstances?

Whether the lower court’s factual findings were supported by substantial evidence, taking into account the alleged errors in the reconsideration process and substantial evidence standard.