Title
Dee C. Chuan and Sons, Inc. vs. Benito Nahag, et al.
Case
G.R. No. L-7211
Decision Date
Sep 22, 1954
A 1953 labor dispute involving Dee C. Chuan & Sons, Inc., where the Court upheld the closure of a lumber department due to financial losses but ordered separation pay for laborers due to lack of proper notice.

Case Summary (G.R. No. L-7211)

Facts of the Case

The Court of Industrial Relations had ordered the Company to pay one month of separation pay to Nahag and his co-workers based on their respective basic wages at the time of lay-off. Additionally, the court approved the closure of the lumber department, stipulating that should this department reopen in the future, laid-off employees must be given priority for re-employment. The Company contested the order for separation pay, deeming it unjust, while the laborers appealed the approval of the department's closure, arguing it was not justified financially.

Background of Disputes

The laborers, represented by an unregistered labor union, had previously secured favorable decisions in multiple cases regarding their employment conditions, culminating in Supreme Court decisions that ratified these favorable findings. As negotiations unfolded in 1951, the Company signaled its intention to close the lumber department, prompting the laborers to file an urgent petition for injunction, seeking to prevent this closure.

Court Findings on Financial Viability

The Court of Industrial Relations concluded that the lumber department incurred significant net losses in 1951 amounting to P245,922.90. The Company’s financial reports demonstrated that its liabilities surpassed its current assets, substantiating the court's findings regarding the department's viability. The laborers’ assertion that the closure maneuvering was an attempt to evade compliance with prior court rulings on wage increases and leave was not validated by the evidence provided.

Jurisdictional Limitation on Review

The Supreme Court characterized the current appeals as questions of law rather than fact, noting that it could only intervene when a significant legal error existed, or when the lower court's findings were demonstrably unsupported by evidence. The Supreme Court emphasized that it would not alter the factual determinations made by the Court of Industrial Relations unless egregious abuse of discretion were evident.

Legal Principles on Separation Pay

The Company’s challenge regarding the mandatory one month separation pay hinged upon its claim of having provided adequate notice prior to the closure, which would absolve it of such obligations. However, the court established that such notice was neither

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