Case Summary (G.R. No. 161135)
Applicable Law
The case is governed by the Labor Code of the Philippines and the 1987 Philippine Constitution concerning the rights of workers to organize and engage in collective bargaining. The Labor Code outlines the procedural requirements for strikes, while the success of union activities is dependent upon compliance with both the procedural and substantive legal standards.
Background and Collective Bargaining Negotiations
In 1994, petitioners and respondents entered into a Collective Bargaining Agreement (CBA) that was set to expire in April 1996. The respondents proposed economic and non-economic proposals for a new CBA in March 1996, which were rejected by FEU-NRMF in May of the same year, leading to failed negotiations despite conciliation efforts through the National Conciliation and Mediation Board (NCMB). The withdrawal of progress in negotiations culminated in the union filing a Notice of Strike due to a bargaining deadlock.
Strike Action and Legal Proceedings
Respondents conducted a strike on September 6, 1996, asserting a lack of acceptance of a skeletal workforce offered to maintain hospital operations during the strike. Concurrently, FEU-NRMF petitioned the National Labor Relations Commission (NLRC) for the assumption of jurisdiction, which was granted, prohibiting strikes and commanding the union to return to work.
The dispute escalated with the union continuing its strike despite a subsequent order from the Secretary of Labor directing the employees to return to work. FEU-NRMF claimed that the strike was illegal, citing the blockade of hospital entrances, which obstructed patient access and endangered lives.
Initial Rulings and Subsequent Appeals
The Labor Arbiter ruled the strike illegal and dismissed union officers for their involvement. The NLRC affirmed this decision, stating that the union violated the Assumption of Jurisdiction Order by continuing the strike, which justified the employees' loss of employment status.
Respondents appealed the NLRC's resolution to the Court of Appeals, arguing that the dismissal of union officers was unjust and that due process was violated as they were not properly notified of the Assumption of Jurisdiction Order.
Court of Appeals Decision
The Court of Appeals found that the method of serving the Assumption of Jurisdiction Order was invalid. The process server's act of posting the Order rather than delivering it personally or through registered mail did not comply with legal standards for notification. Consequently, the appellate court reversed the NLRC's ruling, asserting that the union officers could not be considered to have defied the Order since they had not been properly informed.
Supreme Court Findings and Conclusion
Upon review, the Supreme Court evaluated whether the servic
...continue readingCase Syllabus (G.R. No. 161135)
Case Background
- The case involves a petition for review on certiorari filed by the Far Eastern University - Dr. Nicanor Reyes Medical Foundation (FEU-NRMF) challenging the decisions of the Court of Appeals.
- The petition was brought against the FEU-NRMF Employees Association-Alliance of Filipino Workers (FEU-NRMFEA-AFW) and several union officers and members.
- The primary issues pertain to a labor strike that occurred following a failure in collective bargaining negotiations and the subsequent legal ramifications regarding the strike's legality and the employment status of the union officers.
Procedural History
- A Collective Bargaining Agreement (CBA) between FEU-NRMF and the union expired on April 30, 1996.
- The union proposed a new CBA on March 21, 1996, but FEU-NRMF rejected most of the demands citing financial constraints.
- Following failed conciliation proceedings, the union filed a notice of strike on August 6, 1996, resulting in a strike that commenced on September 6, 1996.
- FEU-NRMF filed a petition for the assumption of jurisdiction over the labor dispute, which was granted by the Secretary of Labor, prohibiting any strike or lockout.
Service of Assumption of Jurisdiction Order
- The process server attempted to serve the Assumption of Jurisdiction Order on September 5, 1996, but was unable to do so personally and instead posted copies on the premises of FEU-NRMF.
- The Court examined whet