Title
Castro vs. Philippine Long Distance Telephone Co.
Case
G.R. No. 191792
Decision Date
Aug 22, 2012
PLDT employees dismissed after an illegal strike sought CBA benefits post-termination; SC ruled they were no longer employees when CBA took effect, requiring return of P133,000.

Case Summary (G.R. No. 230904)

Factual Antecedents

The case revolves around the unlawful dismissal of the petitioners, who were union officers of PLDT. The dismissals were a result of their participation in a strike from December 22, 1992, to January 21, 1993, declared illegal. Subsequently, the NLRC's February 27, 1998 ruling declared the dismissals valid, which was upheld by the Supreme Court on August 3, 1998. The petitioners contended that during the interim between their return to work in April 1993 and their dismissal in 1999, PLDT had provided certain benefits to other employees, signifying a potential waiver of their illegal strike's repercussions.

Procedural History

Petitioners filed complaints for illegal dismissal and damages, which were consolidated. The Labor Arbiter issued a March 15, 2000 decision which rejected PLDT's defense of res judicata, deeming the dismissals illegal due to PLDT's granting of benefits during the employees' reinstatement. This decision was vacated by the NLRC on December 28, 2000, asserting that the conditions for condonation were not met, although some financial assistance was provided to the affected employees. Following unsuccessful appeals, petitions were filed for certiorari before the CA, ultimately leading to a new Collective Bargaining Agreement (CBA) signed on March 14, 2001, retroactive to November 9, 2000.

NLRC and CA Rulings

The NLRC order on April 18, 2002 authorized the payment of P133,000 to each affected employee under the CBA, but the CA later vacated this order, ruling that the petitioners could not claim benefits from a CBA of which they were not members at the time of its signing, given their employment terminations had been confirmed as valid.

Issue Before the Court

The key issue was whether the petitioners were entitled to the CBA benefits despite their earlier termination. While the petitioners argued that the CBA's effectiveness prior to the NLRC decision justified their claims, the respondents contended that the CBA only applied to current employees as of March 14, 2001, when the agreement was finalized.

Court’s Ruling

The Court affirmed the CA's decisions, emphasizing that collective bargaining benefits are exclusive to employees who are active members of the bargaining unit. Given the final ruling of the Supreme Court on January 18, 1999, confirming the petitioners&#

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