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
...continue readingCase Syllabus (G.R. No. 219059)
Background of the Case
- The case arises from a Petition for Review on Certiorari filed by petitioners Gaudioso Iso, Jr. and Joel Tolentino against Salcon Power Corporation (now SPC Power Corporation) and Dennis Villareal.
- The petition seeks to overturn the Decision dated October 9, 2013, and the Resolution dated May 13, 2015, of the Court of Appeals (CA) in CA-G.R. CEB-SP Nos. 02781 and 06429.
Antecedents of the Cases
- The two consolidated cases involve labor disputes related to the dismissal of petitioners from their positions at Salcon Power Corporation.
- In CA-G.R. CEB-SP No. 02781, the petitioners challenge the decision of the National Labor Relations Commission (NLRC) which upheld their dismissal for serious misconduct.
- The petitioners had previously executed a Compromise Agreement with the respondent, which they claimed should not affect their case because they were not signatories to the agreement.
- In CA-G.R. CEB-SP No. 06429, the petitioners, as union officers of the Salcon Power Independent Union (SPIU), filed a complaint for illegal dismissal after being terminated for allegedly making libelous statements against the company during a press conference.
Details of the Dismissal
- The petitioners faced accusations of serious misconduct for uttering libelous statements regarding the company’s finances during a press conference held on May 27, 2009.
- The statements made by the petitioners, which were published in a newspaper, alleged that SPC Power Corporation had overcharged consumers and profited at the government’s expense.
- The Labor Arbiter (LA) concluded that the petitioners were not wrongfully dismissed, finding substantial evidence to