Title
Talisay Employees' and Laborers' Association vs. Court of Industrial Relations
Case
G.R. No. L-39844
Decision Date
Jul 31, 1986
Rival unions TELA and FVW clashed over TASIMICO's labor practices; FVW won certification, led a strike, and leased Central to TASICA. TELA sued for unfair practices; SC ruled TASICA liable, limited backwages to 3 years, and ordered TASIMICO to rehire TELA members preferentially.
unfair labor practice
backwages
labor organization
A

Case Digest (G.R. No. L-39844)

Facts:

  • Parties and Organizations
    • Petitioners:
      • Talisay Employees' & Laborers' Association (TELA), a legitimate labor organization with Felipe B. Lacson as its president.
    • Respondents:
      • Talisay Silay Milling Co., Inc. (TASIMICO), a domestic corporation operating a sugar mill in Talisay, Negros Occidental.
      • Talisay Silay Industrial Cooperative Association (TASICA), composed of workers of TASIMICO and duly registered with the Cooperative Administrative Office.
      • Free Visayan Workers (FVW), another legitimate labor organization initially led by Jose Treyes (later succeeded by Amado F. Rivera), serving as the collective bargaining representative after winning a certification election.
      • Other individuals including J. Amado Araneta (president) and Alfredo Banas (resident manager) connected with the operations and management of TASIMICO.
  • Background and Certification Election
    • On February 22, 1963, a certification election was held at the Central of TASIMICO where:
      • FVW won over TELA and was duly certified as the collective bargaining unit.
      • The result of the election was not contested by any of the parties.
    • FVW demanded that the company lease the Central to TASICA, an association already organized and registered earlier (April 2, 1962).
  • The Strike and Its Aftermath
    • Due to TASIMICO’s failure to address FVW’s demands, the union initiated a strike on April 15, 1963.
      • TELA members, however, did not join the strike.
      • Picket lines were maintained by FVW members during the strike.
    • During the strike period:
      • TASIMICO continued milling during the 1962-63 crop year.
      • Two conciliation conferences took place involving Department of Labor representatives, TASIMICO, and FVW with Banas also present.
    • Resolution of the Strike:
      • On April 18, 1963, TASIMICO entered into a lease contract with TASICA in an effort to settle the dispute.
      • The strike was finally settled on April 29, 1963.
      • Wage payments:
        • Both TELA and FVW members received wages for April 1–14, 1963.
        • Only FVW members received strike duration pay for April 15–29, 1963.
  • Government Intervention and Resumption of Operations
    • On May 2, 1963, the Central was placed under the control of the Armed Forces of the Philippines under Major General Pedro Q. Molina pursuant to Presidential Proc. No. 106.
    • Subsequent legal actions included:
      • A petition by the Solicitor General (filed on May 3, 1963) for appointment of an administrator of the Central.
      • The denial of said petition on May 4, 1963, with an order for TASIMICO and TASICA to resume operations within ten days.
    • Operational Changes:
      • Resumption on May 14, 1963, under military supervision.
      • Appointment of Sugar Quota Administrator Conrado Manalansan on May 31, 1963, and eventual termination of milling operations on June 5, 1963.
  • Filing of the Complaint and Proceedings in the Court of Industrial Relations (CIR)
    • On July 19, 1963, acting for TELA, a complaint was filed with the CIR alleging unfair labor practices by TASIMICO, TASICA, and Amado Araneta. The allegations included:
      • Aiding FVW in the certification election to secure majority votes.
      • Discriminatory actions against TELA members in terms of salary increases, union dues collection, and distribution of rice rations and other benefits.
      • Abetting the establishment of TASICA as a cooperative to undermine TELA.
      • Leasing the Central to TASICA as a pretext to exclude TELA members from work.
      • Instigating the strike and preventing TELA from returning to work.
      • Ordering TELA members to show identification cards issued by TASICA for re-admittance.
    • Findings in the Initial Decision:
      • The trial court dismissed most charges for lack of sufficient evidence except for discriminatory practices after the strike, particularly the refusal to re-admit TELA members.
      • The court ordered the reinstatement of individual complainants with backwages from April 15, 1963 to November 24, 1967.
    • En Banc Modification by the CIR:
      • Upon motions for reconsideration, the CIR sitting en banc affirmed the trial court’s findings but modified the liability:
        • Found only TASICA guilty of unfair labor practice and liable for backwages (limited to three years from April 29, 1963—the period during which the lease was in effect).
        • TASIMICO, although absolved of direct liability for backwages, was directed to re-admit the individual complainants on a preferred basis.
  • History of the Appeal to the Supreme Court
    • Petitioners filed a petition for certiorari and review challenging the CIR's en banc resolution.
    • The petitioners raised six main assignments of error, which included:
      • Alleged error in not finding all respondents jointly liable for unfair labor practices and backwages.
      • Error in the determination of the validity and effect of the lease contract between TASIMICO and TASICA.
      • Error in the limitation of the backwage period to three years.
      • Error in the manner of ordering the reinstatement of the affected workers.
      • Error in not awarding the petitioners the funds corresponding to their 15% salary increase, which had been deposited with the court.
    • The Supreme Court review involved scrutiny of the detailed findings and evidence presented by the Hearing Examiner (which included testimony of 66 witnesses and over 3,400 exhibits), as well as arguments from both petitioners and respondents.

Issues:

  • Whether the findings of fact of the Court of Industrial Relations (CIR), as adopted by the trial court and confirmed en banc, are reviewable on the grounds alleged by the petitioners.
  • Whether the lease contract between TASIMICO and TASICA, executed with all requisite formalities and holding valid for all legal and contractual purposes, exonerates TASIMICO from liability for back wages and responsibility for discriminatory practices.
  • Whether the determination of sole and exclusive responsibility for the unfair labor practice on the part of TASICA (specifically, the discriminatory act of refusing to re-admit TELA members) is supported by substantial evidence.
  • Whether fixing the period for backwage recovery to three years (corresponding to the term of the lease contract) is legally and equitably justified.
  • Whether the order directing TASIMICO to re-admit TELA members “on a preferred basis” is appropriate, considering the operational circumstances post-strike.
  • Whether the petitioners are entitled to receive the funds corresponding to their 15% salary increase, which had been deposited with the court, given that such increases were withheld pending resolution of the dispute.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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