Title
Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas vs. Saw Mill
Case
G.R. No. L-1573
Decision Date
Mar 29, 1948
Labor strike at Gotamco Saw Mills led to a temporary wage agreement, but union violated court order with another strike. Court upheld constitutionality of labor law, exonerated company, and justified worker dismissal.
labor dispute
union
saw mill company

Case Summary (G.R. No. L-1573)

Factual Background

A labor dispute involving the employees of Gotamco Saw Mills culminated in a strike declared on September 10, 1946. The dispute had been certified by the Department of Labor to the Court of Industrial Relations on September 14, 1946. After preliminary hearings and conferences, the parties negotiated a temporary settlement on September 23, 1946, under which the striking laborers agreed to return to work on September 24, 1946. The court approved the agreement and ordered the workers to resume employment. The agreement provided for an over-all increase of P2.00 daily without meal, permission for laborers to take small pieces of lumber for firewood when available, and a stay of strikes or walkouts pending final determination.

Proceedings in the Court of Industrial Relations

On January 7, 1947, Gotamco Saw Mills sought contempt proceedings against the union for staging a strike during the pendency of the main case, alleging violation of the court’s September 23, 1946 order. The union answered on January 9, 1947, and counter-petitioned, alleging that the company had ordered a stoppage of work in a haughty and arbitrary manner and asking that the respondent be held in contempt for employing four Chinese laborers in violation of Section 19 of Commonwealth Act No. 103, as amended. The respondent also filed an urgent motion charging picketing and threats that prevented remaining laborers from working. The Court of Industrial Relations required the parties to present evidence on these incidents.

Findings and Orders of the Court of Industrial Relations

By order of March 28, 1947, the Court of Industrial Relations framed the issues to include whether the union violated its September 23, 1946 order; whether picketing constituted contempt; whether respondent violated Section 19 by hiring four Chinese laborers; and whether a dismissal of a particular worker, Maximino Millan, was with or without just cause. The court found that the union had violated its September 23 order and directed its special agent to take appropriate action for contempt. The court treated the picketing issue as subsumed by the finding on the strike. It exonerated the respondent for lack of strong and clear proof of violation of Section 19 in hiring four Chinamen. The court denied the reinstatement claim of Maximino Millan on grounds of his troublesome character.

Reconsideration and Resolution

The union sought reconsideration. In its July 11, 1947 resolution, the Court of Industrial Relations denied reconsideration and addressed the union’s contention that the September 23 order had not complied with Section 19 because there had been no proper hearing and no express finding that public interest required the return of striking workers. The court also recorded the union’s constitutional challenge that Section 19 authorized involuntary servitude. The Court of Industrial Relations rejected these contentions, held that the September 23 order conformed to Section 19, and explained that the preliminary hearings constituted hearings within the meaning of the statute. The court also observed that the union had accepted and benefited from the order and could have appealed timely if aggrieved.

Questions Presented to the Supreme Court

The petition for a writ of certiorari asked this Court to reverse and vacate the Court of Industrial Relations’ orders of September 23, 1946 and March 28, 1947 and its July 11, 1947 resolution. Central legal issues included whether the Court of Industrial Relations complied with statutory requisites for issuing an order under Section 19, whether Section 19 violates the constitutional prohibition against involuntary servitude, and whether the Supreme Court was barred from reviewing findings of fact made by the Court of Industrial Relations.

The Supreme Court’s Disposition

The Supreme Court, en banc, affirmed the orders and the resolution of the Court of Industrial Relations and imposed costs against the petitioner-appellant. The Court declined to disturb the factual findings of the Court of Industrial Relations.

Legal Basis and Reasoning on Statutory Compliance

The Supreme Court agreed with the Court of Industrial Relations that the September 23, 1946 order was issued in conformity with Section 19. The Court recognized that the temporary settlement emerged from a series of preliminary hearings and conferences that were reported at formal hearings. The Court observed that the record showed prolonged proceedings and incidents after certification on September 14, 1946, which demonstrated that the main case had not been promptly decided or settled. The Court reasoned that when a dispute cannot be promptly decided or settled, the statute authorizes the Court of Industrial Relations, after hearing, to order striking workers to return to work. The Court held that the absence of an express statement in the September 23 order as to public interest did not invalidate the order because the impossibility of prompt decision was evident from the record.

Legal Basis and Reasoning on Constitutionality

Confronting the union’s constitutional challenge, the Supreme Court upheld Section 19 of Commonwealth Act No. 103 against the claim that it amounts to involuntary servitude. The Court began from the presumption of constitutionality of statutes. It explained that the statutory scheme was an exercise of the State’s police power to regulate conditions in furtherance of social justice and economic rehabilitation. The Court emphasized that employees who enter into contracts of employment after the statute’s enactment do so voluntarily and thereby accept the implied condition that, when a dispute is submitted to the Court of Industrial Relations, they will not strike when enjoined after hearing and when public interest requires, or when the dispute cannot be promptly decided or settled. The Court concluded that this voluntariness negated any claim of involuntary servitude.

Public Interest and the Post‑War Context

The Court specifically relied on the public interest in the lumber industry after the war. It took judicial notice of the urgent need for building materials to achieve national reconstruction and found that undue stoppage of lumber production would impede rehabilitation. The Court considered this public interest as a proper basis for the Court of Industrial Relations to enjoin a strike or to order the return of workers when statutory conditions were met.

Deference to Findings of Fact

The Supreme Court reaffirmed its statutory and jurisprudential stance against reviewing findings of fact made by the Court of Industrial Relations. The Court cited the statutory limitations on review, invoking Section 15 of Commonwealth Act No. 103, as amended by Commonwealth Act 559, and applicable procedural rules and prior decisions. It held that it was not authorized to retry factual determinations made by that administrative tribunal.

Cited Precedent and Statutory Interpretation

In support of its reasoning, the Court quoted and relied upon earlier decisions sustaining the powers of the Court of Industrial Relations, including the principle that jurisdiction under Section 19 is incidental to the court’s broader powers and that the power to execute its orders includes the power to enforce them. The Court cited decisions such as Manila Trading and Supply Co. vs. Philippine Labor Unio

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