Title
Source: Supreme Court
Iso, Jr. vs. Salcon Power Corp.
Case
G.R. No. 219059
Decision Date
Feb 12, 2020
Employees dismissed for libelous statements; SC upheld dismissal, citing serious misconduct, management prerogative, and due process compliance.

Case Summary (G.R. No. 219059)

Antecedents

The petition stems from two consolidated cases. In CA-G.R. CEB-SP No. 02781, the petitioners challenged the National Labor Relations Commission's (NLRC) decision from 2006 regarding their dismissal. Subsequently, several other petitioners reached a compromise with the respondent in 2009, which resulted in dismissal of their claims. In CA-G.R. CEB-SP No. 06429, the petitioners, as union officers, allege retaliatory dismissal for their collective bargaining efforts. The prior Labor Arbiter ruled against them, finding sufficient grounds for dismissal due to their conduct during a press conference.

Summary of Key Events

Petitioners asserted their rights as union officials of the Salcon Power Independent Union (SPIU) to engage in collective bargaining. After a certification election, the SPIU was recognized as the employees' negotiation representative. However, during ongoing negotiations, the respondent's refusal to discuss a collective bargaining agreement led the SPIU to threaten a strike, culminating in a press conference where the petitioners made statements about the alleged financial improprieties of the respondent. This led to the issuance of show-cause notices, subsequent hearings, and finally, their dismissal for serious misconduct.

Labor Arbiter's Decision

The Labor Arbiter found that the petitioners had committed serious misconduct by making libelous statements during a press conference, which were separate from their union activities. Their statements were broadcasted in the media, leading to criminal charges against them for libel. The Labor Arbiter ruled that they were validly terminated based on their actions rather than any exercise of protected union rights.

NLRC and Court of Appeals Rulings

The NLRC upheld the Labor Arbiter's decision, affirming that the petitioners’ actions constituted serious misconduct. It found that the evidence supported the claims of libel and serious breaches of trust, which justified their termination. The Court of Appeals later affirmed these findings, dismissing the petitioners' claims as lacking in merit and reiterating that their dismissal was a valid exercise of management prerogative.

Petitioners' Arguments

In their petition for review, the petitioners argued that their length of service warranted a lesser penalty than dismissal and that their remarks were made in good faith during the heat of union negotiations. They contended that their statements were matters of public interest and constituted fair comment, thus protected under freedom of expression. They also claimed that the findings of the NLRC and the CA were erroneous.

Respondents' Arguments

The respondents countered that the petition presented factual questions rather than legal issues and that the petitioners were terminated legitimately based on serious misconduct. They asserted that the NLRC acted within its jurisdiction without any abuse of discretion and stressed that the factual findings should be respected, particularly since the petitioners held superviso

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