Case Summary (G.R. No. L-26796)

Nature of Certification Proceedings

• Certification proceedings are characterized as non-adversarial and fact-finding investigations.
• The investigating agency acts as a disinterested investigator to ascertain employees' desires regarding representation.

Voting Eligibility and Employment Status

• The order specifying who could vote in the certification election does not conclusively determine the employment status of those excluded from voting.
• Employees not allowed to vote retain the right to contest their employment status in subsequent unfair labor practice cases.

Dismissal Issues Not Merged

• The denial of an injunction to allow certain workers to vote does not merge the issue of their dismissal with the certification proceeding.
• The dismissal of employees, alleged to be an unfair labor practice, must follow a distinct legal procedure and cannot be conflated with certification proceedings.

Res Judicata Not Applicable

• There is no identity of parties between the two unfair labor practice cases cited by petitioners.
• The circumstances surrounding each employee's dismissal are different, thus precluding the application of res judicata.

Conclusive Findings of the Industrial Court

• The factual findings of the Court of Industrial Relations, supported by substantial evidence, are conclusive and cannot be reversed by the Supreme Court unless there is grave abuse of discretion.

Supreme Court's Review Authority

• The Supreme Court's review of decisions from the Court of Industrial Relations is limited to questions of law, not factual determinations based on substantial evidence.

Unfair Labor Practices Defined

• Management's refusal to allow employees to work unless they dissociate from the union constitutes an unfair labor practice.

Backwages Award Justification

• The award of backwages exceeding six months is justified due to the absence of changes in ownership or cessation of operations at Bulakea Restaurant, distinguishing it from previous cases that limited backwages.

Background of the Case

• The complainant union was organized among Bulakea employees, and grievances were raised regarding employment conditions.
• The six complaining members were dismissed after expressing their union membership, which they allege was the reason for their termination.

Petitioners' Arguments

• Petitioners argue that the employees lost their status as employees and that previous case outcomes should affect the current case.
• They also claim that the dismissals were justified and that the employees abandoned their jobs.

Court's Findings on Employment Status

• The court found that the certification proceeding does not determine employee status conclusively.
• The denial of the injunction does not prevent the employees from contesting their dismissals.

Res Judicata Analysis

• The court determined that the two unfair labor practice cases involved different sets of employees and circumstances, nega...continue reading