Case Summary (G.R. No. 101858)
Procedural History
In response to the strike notice, Batangas Laguna Tayabas Bus Company requested the Secretary of Labor to assume jurisdiction over the dispute, which led to certification to the National Labor Relations Commission (NLRC) for compulsory arbitration on August 29, 1988. Despite receiving the certification, the union proceeded with the strike on August 31, 1988, compelling the NLRC to issue a resolution on September 6, 1988, ordering the strikers to lift their picket lines and return to work.
NLRC Resolutions
The NLRC's subsequent resolutions, particularly those dated July 19, 1991, and September 16, 1991, rendered significant rulings on the legality of the strike and the employment status of the union members. The July resolution declared the strike illegal and upheld the dismissal of certain employees while also ordering the reinstatement of union members who did not commit illegal acts during the strike. The September resolution affirmed the previous orders and provided clarity on the reinstatement process.
Allegations of Illegal Actions
Batangas Laguna Tayabas Bus Company contended that the reinstated union members participated in an illegal strike, arguing that their failure to comply with the return-to-work order constituted abandonment of their employment. The company claimed the NLRC erred by failing to include additional employees who supposedly committed violent acts during the strike in the forfeiture of employment status.
NLRC’s Reasoning
The NLRC defended its decisions by asserting that not all union members were adequately notified about the assumption order, and only the union leaders, who are seen as primarily responsible for the illegal strike, should face employment forfeiture. The Commission maintained that while the majority returned to work, the failure of some to meet the return date should not automatically equate to job abandonment.
Judicial Review and Findings
Upon reviewing the NLRC resolutions, the court found no grave abuse of discretion in the decisions. The court emphasized that legitimate labor rights, including the right to strike, must be upheld, and employees exercising these rights should not be unreasonably penalized. The assertion that a strike is illegal du
...continue readingCase Syllabus (G.R. No. 101858)
Case Background
- Date of Decision: August 21, 1992
- Case Number: G.R. No. 101858
- Parties Involved:
- Petitioner: Batangas Laguna Tayabas Bus Company (BLTBCo)
- Respondents: National Labor Relations Commission (NLRC), Tinig at Lakas ng Manggagawa sa BLTB Co. NAFLU, and 190 individual union members.
Factual Overview
- On May 23, 1988, the private respondent union filed a Notice of Strike against BLTBCo, citing unfair labor practices and violations of the collective bargaining agreement (CBA).
- In response, BLTBCo sought the Secretary of Labor’s intervention for compulsory arbitration, moving to dismiss the strike notice on August 3, 1988.
- The Secretary of Labor certified the dispute to the NLRC on August 29, 1988, after failed attempts at amicable settlement.
- Despite receiving the certification order, union officers, particularly Jerry Soriano, refused to acknowledge it, leading to a strike commencing on August 31, 1988.
NLRC's Orders and Resolutions
- On September 6, 1988, the NLRC resolved to order the striking employees to lift their picket lines and return to work under previous conditions.
- BLTBCo published the NLRC resolution, calling employees back to work by September 19, 1988.
- Out of approximately 1,730 striking employees, only 1,116 returned, leading to individual complaints of illegal dismissal by those who did not return.
NLRC's Resolution on Dismissal Complaints
- On July