G.R. No. 242904-05 - Datem, Inc. vs. Alphaland Makati Place, Inc.

Case Digest (G.R. No. 242904-05)
Expanded Legal Reasoning Model

Facts:

Background and Parties

Petitioners:

Union of Filipro Employees (UFE)
Seventy union officers and one member

Respondents:

Nestle Philippines, Inc. (formerly Filipro, Inc.)
National Labor Relations Commission (NLRC) and its presiding Labor Ministers and Labor Arbitrators
Several named union officers subsequently declared to have lost their employment status

Nature of the Dispute:

Alleged illegal strikes, walkouts, and other concerted activities by UFE and its officers
Claims that the strike was initiated in response to management’s alleged non-compliance with labor standards and the collective bargaining agreement (CBA)
Allegations of unfair labor practices and subsequent criminal charges arising from the union’s actions

Chronology of Events and Proceedings

Initiation of Labor Dispute

November 14, 1985 – UFE filed a notice of strike (BLR-NS-11-344-85) with the Bureau of Labor Relations against Filipro (later Nestle)
December 4, 1988 – UFE filed a complaint for Unfair Labor Practice (ULP) alleging violations of the Labor Code and non-implementation of CBA provisions

Assumption of Jurisdiction and Issuance of Orders

December 11, 1985 – Minister Blas F. Ople assumed jurisdiction over the dispute pursuant to Article 264(g) of the Labor Code and issued an order enjoining any concerted strike or lockout
January 30, 1986 – A second return-to-work order was issued by Minister Ople, directing striking workers to resume work within 48 hours and instituting measures for hearings and recommendations
March 13, 1986 – Minister Augusto B. Sanchez’s subsequent orders resulted in the striking workers returning to work and later, a withdrawal of UFE’s petition for certiorari concerning Minister Ople’s jurisdiction

Subsequent Incidents and Multiple Cases

Various incidents of strikes, walkouts, and picketing occurred at Nestle’s facilities in Makati, Alabang, Cabuyao, and Cagayan de Oro despite the issued orders
Multiple cases were filed before the NLRC and Labor Arbiters:

NLRC Cases NCR-12-4007-85 and NCR-1-295-86 – declared the strike illegal, held certain union officers liable (loss of employment status), and ordered reinstatement of some employees without backwages

ii. RAB-X-2-0047-86 – affirmed the dismissal of several individual union officers iii. NCR-00-09-0385-87 – involved a series of walkouts and illegal strike petitions where reinstatement was granted in one instance but the overall illegal nature of the strike was upheld

UFE’s subsequent appeal contested the legality of the strike and questioned the jurisdiction and interpretation of Articles 263 and 264 of the Labor Code

Allegations and Contentions of the Petitioners

Grievance Against NLRC’s Affirmance

UFE alleged grave abuse of discretion by NLRC in upholding the Labor Arbiters’ decisions
They maintained that the return-to-work orders ordered under Articles 263 and 264 were improperly applied

Constitutional Argument

UFE contended that Articles 263 and 264 of the Labor Code have become inapplicable or unconstitutional under the 1987 Constitution
They argued that the provisions were based on the 1973 Constitution and hence should no longer prevail

Strike Legality and Participation

UFE claimed that their actions did not constitute an illegal strike since:

They alleged the non-payment of holiday pay and other wage-related issues (violations of labor standards) triggered the strike

ii. They argued that the “no-strike/no lockout” provision applied strictly to economic strikes and that their motives were not solely economic

They further asserted that there were no specific, individualized findings that would render union officers automatically liable under the principle of vicarious liability

Factual Determinations by the NLRC and Labor Arbiters

Violation of the Collective Bargaining Agreement (CBA)

The strike was held to be in violation of the “no strike/no lockout” clause in the CBA
Required procedural steps such as proper notice, cooling-off periods, and strike votes were not strictly observed

Continued Defiance of Return-to-Work Orders

Despite multiple orders from successive Labor Ministers (Ople, Sanchez, and Secretary Drilon), UFE persisted in their strike and other walkout actions
Such defiance resulted in disruptions of company operations and economic losses

Commission of Illegal Acts

Acts involving coercion, intimidation, and use of violence were observed during the strike
Criminal charges were filed in connection with these actions, reinforcing their characterization as illegal under the Labor Code

Issues:

Jurisdictional and Constitutional Validity

Whether Articles 263 and 264 of the Labor Code remain valid and applicable under the 1987 Constitution despite UFE’s contention that these provisions have been superseded.
Whether the assumption of jurisdiction and the certification orders made by the Labor Minister (and subsequently enforced by the NLRC) were proper exercises of authority under the police power of the State.

Legality of the Strike and Labor Actions

Whether the strike, walkouts, and sitdown strikes conducted by UFE and its members were legal, given the mandatory procedures and cooling-off periods of the CBA and Labor Code.
Whether the continued participation in strike activities following the issuance of return-to-work orders constitutes a breach justifying the termination of employment.

Liability of Union Officers and the Doctrine of Vicarious Liability

Whether the union officers should be held liable for the illegal acts (coercion, intimidation, etc.) committed during the strike even in the absence of individualized findings of participation.
Whether the application of vicarious liability in this context is supported by established labor law principles or should be reconsidered.

Procedural and Evidentiary Matters

Whether the NLRC and the Labor Arbiters committed grave abuse of discretion in affirming the decisions aimed at enforcing the return-to-work orders and penalty of dismissal.
Whether the factual record sufficiently establishes that UFE and its officers violated the procedural steps contemplated under both the CBA and the Labor Code.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. 242904-05) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 242904-05)
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Case Digest (G.R. No. 242904-05)
Expanded Legal Reasoning Model