G.R. No. 165407 - Inguillo vs. 1st Philippine Scales, Inc.

Petitioners Herminigildo Inguillo and Zenaida Bergante were employed by First Philippine Scales, Inc. (FPSI) as assemblers.
They were members of the First Philippine Scales Industries Labor Union (FPSILU), which entered into a Collective Bargaining Agreement (CBA) in 1991.
During the CBA's duration, both petitioners joined a rival union, the Nagkakaisang Lakas ng Manggagawa (NLM), leading to an intra-union dispute.
FPSILU filed a complaint against NLM, resulting in a decision favoring FPSILU and ordering NLM to return union dues.

On March 18, 1996, FPSILU requested FPSI to terminate several employees, including Inguillo and Bergante, citing disloyalty and other grounds.
Respondents terminated the petitioners on May 16, 1996, leading to complaints for illegal dismissal filed by the petitioners and other employees.
The Labor Arbiter dismissed the complaints, ruling that the petitioners were not illegally dismissed due to their violation of the Union Security Clause in the CBA.

The National Labor Relations Commission (NLRC) initially reversed the Labor Arbiter's decision, ordering reinstatement and back wages for the petitioners.
Respondents filed a motion for reconsideration, which the NLRC later granted, reinstating the Labor Arbiter's decision and declaring the dismissals valid.
The Court of Appeals affirmed the NLRC's ruling, emphasizing the legality of the Union Security Clause and the petitioners' obligations under the CBA.

The Union Security Clause in the CBA required employees to maintain membership in FPSILU as a condition of continued employment.
The Court recognized the validity of the Union Security Clause, stating it is a lawful exercise of rights under the CBA and does not violate the right to freedom of association.
The petitioners' actions of joining a rival union and failing to maintain membership in FPSILU constituted grounds for their dismissal.

The Court found that while the dismissals were valid, the procedural due process requirements were not met.
Respondents failed to provide the petitioners with the necessary written notices detailing the grounds for their termination and did not conduct a proper hearing.
The absenc...continue reading