Case Summary (G.R. No. 98043)
Background of Employment and Strike
Complainants Angiwan, Soriano, and Rivera were employed at different times by the Baguio Colleges Foundation and were involved in a strike initiated on March 8, 1988, due to labor disputes. Following the strike, on April 29, 1988, the Secretary of Labor and Employment issued a Return-to-Work Order mandating that all striking employees return to work at the start of the 1988-89 school year under prior conditions.
Directive Issuance and Response
On May 8, 1988, Baguio Colleges Foundation published a directive requiring all striking employees to report to Vice President Corazon Concepcion on May 14, 1988, to comply with the Secretary of Labor's order. However, some employees, including the private respondents, did not see this directive, resulting in their failure to report as instructed.
Disciplinary Actions and Complaints Filed
Consequently, respondents who did not comply received termination letters stating their dismissals were based on willful disobedience of the return-to-work order. The respondents filed complaints against the college's administration, claiming their terminations were illegal.
Labor Arbiter's Decision
On January 8, 1990, the Labor Arbiter ruled in favor of Angiwan, Soriano, and Rivera, ordering their reinstatement without loss of seniority and awarding back wages along with attorney’s fees. The petitioners appealed this decision to the National Labor Relations Commission (NLRC).
NLRC Ruling
On November 29, 1990, the NLRC affirmed the Labor Arbiter's decision, contending that the petitioners had changed the conditions of the Return-to-Work Order and that the dismissals of the employees were illegal. The NLRC noted that the Return-to-Work Order did not authorize the petitioners to impose a new timeframe or dismiss employees who failed to comply with a unilaterally set date.
Legal Analysis of Petitioners' Actions
The petitioners contended that they acted in good faith and were merely accommodating administrative necessities. However, the NLRC found no legal grounds for dismissing employees without proper notification and compliance with the original order issued by the Secretary of Labor.
Supreme Court Review and Findings
The Supreme Court determined that the NLRC did not commit grave abuse of discretion in its findings. The emplo
...continue readingCase Syllabus (G.R. No. 98043)
Case Background
- This case arises from the dismissal of faculty members from Baguio Colleges Foundation (BCF) following their participation in a strike on March 8, 1988.
- The petitioners are BCF, Ray Dean Salvosa, and Corazon Concepcion, while the respondents include Alma Angiwan, Danilo Soriano, and Restituto Rivera.
- Private respondents filed complaints against their dismissals, claiming they were illegal.
Procedural History
- The Labor Arbiter ruled in favor of private respondents on January 8, 1990, ordering their reinstatement and back wages.
- Petitioners appealed the decision to the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's ruling on November 29, 1990.
- Petitioners subsequently filed a petition with the Supreme Court, arguing that the NLRC committed grave abuse of discretion.
Key Facts
- The private respondents were employed at different times: Angiwan (November 1987), Soriano (June 1978), and Rivera (May 1982).
- The Secretary of Labor issued a return-to-work order on April 29, 1988, instructing striking employees to return by the opening of the new school year in June.
- BCF published a directive in their community newspaper, Gold Ore, instructing striking employees to report to Concepcion's