Case Summary (G.R. No. L-23689)
Facts of the Case
The decision of the respondent judge outlines that the respondents were initially employed as farm workers before being appointed to positions as security guards at the hacienda. In April 1963, they affiliated with the Allied Workers' Association. On May 21, 1963, Mayo Lopez Carillo summoned them and imposed a condition that, in order to continue their employment as security guards, they must relinquish their union membership. Failure to comply would result in a transfer to lower-paid farm work. The respondents did not accept this condition, leading them to cease reporting for work, which they alleged constituted constructive dismissal.
Legal Issues Raised
The principal issue determined by the court was whether the hacienda's actions amounted to unfair labor practices. The hacienda's condition requiring the security guards to abandon their union membership was found to discourage their right to organize, a clear contravention of labor rights. The court concluded that such a requirement was a form of discrimination against union members employed in essential positions.
Rulings on Errors Raised
The petitioners assigned three errors in their appeal, primarily contesting the reinstatement of the respondents with back wages. The first error pertained to factual conclusions regarding constructive discharge, while the second error involved a legal argument about the applicability of the Industrial Peace Act and the Land Reform Code, asserting that these were enacted after the events in questions. The court determined that neither error was meritorious. The factual determination regarding unfair labor practices was supported by substantial evidence and could not be disturbed on appeal.
Jurisdictional Considerations
The argument of improper jurisdiction raised by the petitioners was also dismissed. Even though there was a conflicting precedent regarding the classification of security guard work within agrarian relations, the court ruled that procedural timeliness would prevent any challenge to jurisdiction after significant delay. The court emphasized that the complexity of labor relations necessitates adherence to timely processes to
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Case Background
- The case revolves around a decision rendered by Judge Artemio C. Macalino of the Court of Agrarian Relations on September 22, 1964.
- Petitioners Mayo Lopez Carillo, Honey Lopez Panganiban, Benita Lopez, Albina H. Lopez, and Balbino Biado were ordered to reinstate respondents Rafael Didal, Baltazar de Asis, Diego Caballes, and Crispin Buenafe as security guards at Hacienda Fara-on in Cadiz, Occidental Negros.
- The reinstatement included the payment of back wages calculated at a daily rate of Two Pesos and Seventy-five Centavos (P2.75), starting from May 22, 1963, until their actual reinstatement.
Facts of the Case
- Initially, the respondents were employed as farm workers engaged in various agricultural tasks.
- They were later appointed as security guards at the Hacienda.
- In April 1963, these individuals, alongside Sebastian Rizalino, joined the plaintiff Union, which later became the respondent Allied Workers' Association.
- On May 21, 1963, they were summoned by Mayo Lopez Carillo, who informed them that their union membership was incompatible with their roles as security guards, offering them a choice to either relinquish their membership or be transferred to another department with lower wages.
- The plaintiffs found these conditions unacceptable and subsequently chose not to return to work.