Case Summary (G.R. No. L-41518)
Background of the Case
The conflict originated on June 1, 1972, when the United States Naval Base authorities conducted a public bidding for transportation services, resulting in Guerrero's Transport Services winning the contract over Blaylock Transport Services, whose 395 employees were represented by BTEA-Kilusang. On January 1, 1973, when Guerrero commenced operations, it refused to employ the members of the union, prompting the latter to file a complaint with the National Labor Relations Commission (NLRC), which was initially dismissed for lack of jurisdiction.
Progression of the Legal Proceedings
Despite the dismissal on jurisdictional grounds on March 13, 1973, the NLRC was directed by the Secretary of Labor to review the case. Following a series of conferences, the NLRC issued a Resolution on October 31, 1973, ordering Guerrero to absorb applicants from the union into their workforce, with certain exceptions for derogatory records. Subsequently, further appeals and compliance actions ensued, including directions from the Secretary of Labor and requests for reports concerning compliance with the NLRC’s resolutions.
Orders and Compliance Issues
Throughout 1975, various orders were issued by the Labor Arbiter, which included an order on June 20 ordering the reinstatement of 129 individuals and a subsequent motion for execution filed by the union. However, Guerrero contended that the Arbiter lacked jurisdiction over the matter, leading to further complications regarding compliance with reinstatement orders, culminating in a writ of execution on September 25, 1975, mandating Guerrero to reinstate the union members and pay back wages.
Petitioner’s Legal Challenge
In response to the Orders issued by the Labor Arbiter, Guerrero's Transport Services filed a petition for certiorari and prohibition on October 1, 1975, aimed at nullifying these Orders on the grounds of lack of jurisdiction. The Supreme Court issued a temporary restraining order, leading to responses from the Labor Arbiter and the Deputy Sheriff, attempting to justify their actions.
Compromise Agreement and Subsequent Developments
On October 20, 1975, a compromise agreement was reached between the parties, stipulating that the determination of workers to be reinstated would be submitted to the Secretary of Labor, with a resolution from this agreement superseding prior NLRC resolutions. The Secretary of Labor then issued an order on November 13, 1975, directing the NLRC to implement the absorption of 175 union members, subject to specific conditions related to their status as bona fide employees and approval by U.S. Navy authorities.
Implementation of the Secretary's Order
Labor Arbiter Francisco M. de los Reyes subsequently conducted hearings to determine which employees were bona fide prior employees of Blaylock Transpor
...continue readingCase Syllabus (G.R. No. L-41518)
Background of the Case
- The case originates from a public bidding conducted on June 1, 1972, by the United States Naval Base authorities in Subic, Zambales, for a five-year contract to operate and manage transportation services within the naval base.
- Guerrero’s Transport Services, Inc., owned by Santiago Guerrero, won the bidding over the incumbent concessionaire, Blaylock Transport Services, which had 395 employees represented by the respondent union, BTEA-Kilusang.
- Upon commencing operations on January 1, 1973, Guerrero’s Transport Services did not employ members of the respondent union, leading to a complaint filed by the union on January 12, 1975, with the National Labor Relations Commission (NLRC) to compel employment of its members based on the RP-US Base Agreement dated May 27, 1968.
Procedural History
- The NLRC dismissed the union's complaint on March 13, 1973, citing a lack of employer-employee relationship.
- The union appealed, and the case was remanded to the NLRC. A series of conferences followed, culminating in a resolution on October 31, 1973, directing the petitioner to absorb all complainants who applied before a set deadline, except those with derogatory records.
- This resolution was affirmed by Secretary of Labor Blas F. Ople on December 27, 1973.
- The petitioner’s subsequent appeals to higher authorities were returned for action to the Secretary of Labor without a definitive resolution.
Developments and Compliance Issues
- The provincial labor office provided a list of 46 union members eligible for absorption, but compliance was hindered by the failure of some complainants to meet requirements set by the U.S. Naval Base authorities.
- On Jan