G.R. No. L-22219 - Alhambra Industries, Inc. vs. Court of Industrial Relations

Case Citation: 139 Phil. 628 [G.R. No. L-22219. August 28, 1969]
Parties Involved:
- Petitioner: Alhambra Industries, Inc.
- Respondents: Court of Industrial Relations and Kapisanan ng Mga Manggagawa sa Alhambra (PAFLU)
Nature of the Case: Appeal by certiorari concerning an order from the Court of Industrial Relations relating to reinstatement and back wages due to unfair labor practices.

The case stems from a finding of unfair labor practice against Alhambra Cigar and Cigarette Factory Co. on April 3, 1962, which ordered reinstatement of specific employees.
Subsequent corporate changes led to the establishment of Alhambra Industries, Inc., which was deemed the successor.
The order for reinstatement was affirmed multiple times but had not been complied with, prompting the Union to file for enforcement.

Legal Principle: Employers found guilty of unfair labor practices are obliged to reinstate affected employees and pay back wages.
Key Definitions:
- Unfair Labor Practice: Actions by employers that violate the rights of employees or hinder union activities.
- Reinstatement: The act of restoring an employee to their former position or an equivalent one.

Legal Requirement: Successor companies inherit liabilities of their predecessors concerning labor disputes.
Consequences: Alhambra Industries, Inc. was held liable for reinstating employees and paying back wages due to its status as the successor company.

Initial Orders: The Court of Industrial Relations issued an order on April 3, 1962, followed by a reaffirmation on May 30, 1963, which established the obligations of the petitioner.
Motion for Execution: The Union's motion for reinstatement was initially filed on July 6, 1962, followed by a motion on October 4, 1963, to compute back wages.
Petitioner’s Opposition: Alhambra Industries, Inc. filed motions to delay the enforcement of reinstatement, citing the abolishment of the positions held by some employees.

Finality of Orders: The orders regarding reinstatement and back wages were deemed final and executory, leaving no room for further appeals based on grounds already considered.
Fact Findings: The Court affirmed that there was substantial evidence supporting the claim that the positions of certain employees had been available and that the objections raised by the petitioner were not timely.

Rattan Art vs. Rattan Art Union: Established that issues cannot be reopened if they were available during the original proceedings.
National Waterworks and Sewerage Authority vs. NWSA Consolidated Union: Emphasized the importance of adherence to prior rulings in labor cases.

The Supreme Court upheld the order for the reinstatement of employees and the payment of back wages, reinforcing the principle that successor companies are liable for the unfair labor practices of their predecessors.
The decision highlighted the importance of finality in labor disputes and discouraged attempts to