Case Summary (G.R. No. 224945)
Procedural History
On September 24, 1975, the petitioners filed a motion for reconsideration regarding a decision dated September 4, 1975, with the Court subsequently requiring comments from the respondents. Respondent Liberty Cotton Mills, Inc. submitted its comment on October 27, 1975, while PAFLU filed a manifestation of compliance on October 30, 1975. The National Labor Relations Commission followed with its comment on November 5, 1975.
Petitioners' Claims
The petitioners sought the following reliefs in their motion: (1) to hold the respondent company jointly and severally liable for backwages; (2) immediate reinstatement without loss of seniority or benefits, at rates equal to those in 1964; and (3) backwages calculated for either three years without deduction or a lesser amount for the time prior to actual reinstatement.
Court's Decision and Liability
The Court limited the respondent company's liability to immediate reinstatement of the workers and required PAFLU to pay them three years' worth of backwages without deduction. However, the Court found that the respondent company acted in bad faith by hastily dismissing the petitioners. The respondents' actions were characterized as tortious, warranting solidary liability for the dismissal.
Facts of Dismissal
The dismissal followed a resolution on May 17, 1964, in which several union members disaffiliated from PAFLU. PAFLU rejected this disaffiliation, labeling it as void and sought the dismissal of the petitioners based on alleged disloyalty. The company complied with this request immediately after PAFLU’s communication, indicating a lack of due process, as petitioners were not afforded a proper hearing regarding their expulsion or dismissal.
Bad Faith in Dismissal
The Court emphasized that due process must govern dismissal actions. The respondent company favored expediency over fairness, violating the petitioners' rights to due process, self-organization, and security of tenure. The dismissals were executed without a hearing, which underscored the company's bad faith.
Legal Standards and Constitutional Guarantees
The employer's prerogative to dismiss employees is limited by the necessity for fair procedures. The constitutional guarantees of security of tenure and the freedom of association were highlighted as being paramount, emphasizing that contractual provisions could not justify arbitrary terminations.
Union Actions and Responsibilities
The PAFLU's negligence in representing the workers' interests contributed to the circumstances leading to the disaffiliation. The union’s failure to adequately address the concerns of its members further diminished its standing and the justification for its demands for dismissal based on loyalty issues.
Joint and Several Liability
In light of the conspiracy between the respondent company and PAFLU in executing the dismissals, the Court determined that both entities should be jointly liable for backwages owed to the petitioners. The ruling clarified that protections afforded to workers under both constitutional and statutory provisi
...continue readingCase Syllabus (G.R. No. 224945)
Case Citation
- 179 Phil. 317 FIRST DIVISION [G.R. No. L-33987. May 31, 1979]
Parties Involved
- Petitioners: Liberty Cotton Mills Workers Union, Rafael Nepomuceno, Marciano Castillo, Nelly Acevedo, Rizalino Castillo, Rafael Combalicer
- Respondents: Liberty Cotton Mills, Inc., Philippine Association of Free Labor Union (PAFLU), Court of Industrial Relations
Background of the Case
- A motion for reconsideration was filed on September 24, 1975, by the petitioners against a decision dated September 4, 1975.
- The Court required comments from the respondents, with Liberty Cotton Mills, Inc. filing its comment on October 27, 1975, and PAFLU submitting a compliance manifestation without comment on October 30, 1975.
Petitioners' Prayers
- The petitioners sought the following remedies:
- Joint and several liability of the respondent company for backwages.
- Immediate reinstatement of the workers without loss of seniority and benefits, with wages aligned to those of contemporaries in 1964.
- Backwages for a period exceeding three years without deductions or qualifications.
Court's Decision
- The Court's ruling limited the respondent company’s liability to the immediate reinstatement of the petitioners and directed PAFLU to pay three years of backwages without deductions.
- The Court found that the respondent company acted in bad faith during the dismissal of the pe