G.R. No. L-22946 - People vs. Diva

Case Summary (G.R. No. L-22946)

Petitioner and Respondent

Petitioners: MSMG-UWP and its officers, including 30 local union leaders dismissed from employment.
Respondents: Hon. Crescencio J. Ramos (Labor Arbiter), National Labor Relations Commission (NLRC), M. Greenfield, Inc., ULGWP and its officials.

Key Dates

CBA Effective: July 1, 1986–June 30, 1989.
Local Union Election: September 12, 1986.
General Membership Meeting & Proposed Fines: April–July 1988.
Trusteeship Declaration by ULGWP: September–October 1988.
Expulsion of Local Officers & Demand for Dismissal: November 21, 1988.
Termination of Union Officers by Company: March 7, 1989.
Strike by Local Union: Declared March 14, 1989.
Unfair Labor Practice Complaint Filed: August 7, 1989.
Labor Arbiter Decision: December 15, 1992.
NLRC First Division Decision: Denial of reconsideration January 28, 1994.
Supreme Court Decision: February 28, 2000.

Applicable Law

1987 Philippine Constitution: Freedom of association; security of tenure; right to self-organization.
Labor Code, Rule 65: Certiorari jurisdiction.
CBA Union Security Clause (Art. II, Secs. 1, 4).
Serrano v. NLRC (G.R. No. 117040, Jan. 27, 2000): Notice and hearing requirement prior to dismissal.

Background of the Dispute

The CBA between M. Greenfield and ULGWP required all covered employees to maintain union membership as a condition of continued employment. A local union general membership meeting in April 1988 led to fines imposed on absent members. ULGWP disapproved the fines, prompting MSMG-UWP to declare autonomy. In retaliation, ULGWP ordered cessation of education fund remittances and placed the local under trusteeship.

Federation’s Trusteeship and Expulsion

ULGWP appointed an administrator October 1988, “disauthorizing” local officers. After local protests, ULGWP expelled the 30 union officers November 21, 1988 for alleged disloyalty and recommended their dismissal under the CBA’s union security clause.

Company’s Compliance and Termination of Union Officers

Under threat of a federation-instigated strike, M. Greenfield terminated the 30 expelled officers on March 7, 1989, without conducting its own investigation or affording the officers a separate notice and hearing. Security guards physically removed some officers from the premises.

Strike and Subsequent Dismissals

MSMG-UWP filed a strike notice March 8, 1989, to protest the terminations. A referendum produced an overwhelming vote to strike, which commenced March 14, 1989 and involved episodes of violence on both sides. The company suspended and later dismissed numerous participants, citing abandonment of employment after unacknowledged return-to-work notices.

Procedural Posture

The dismissed officers filed an unfair labor practice complaint for union busting, illegal dismissal, discrimination and interference in union activities. The Labor Arbiter dismissed the complaint, finding compliance with the CBA’s union security clause, and the NLRC affirmed. Petitioners then sought certiorari relief before the Supreme Court.

Issue on Due Process and Union Security Clause

Whether M. Greenfield validly dismissed the union officers upon ULGWP’s demand under the union security clause, notwithstanding the company’s failure to conduct its own hearing, and whether such dismissals or the strike constituted unfair labor practice.

Court’s Analysis on Due Process Requirement

The Court affirmed that although union security clauses are enforceable, dismissals thereunder must respect an employee’s right to due process—notice of charges and opportunity to be heard—before termination. A company cannot summarily implement a union’s recommendation without its own independent inquiry.

Court’s Findings on Federation’s Expulsion Authority

While intra-union disputes (expulsion) fall within the Bureau of Labor Relations’ original jurisdiction, the company’s subsequent mass terminations converted the dispute into dismissals, triggering due process requirements. The record showed ULGWP’s constitution did not bar local autonomy; disaffiliation alone did not constitute disloyalty under CBA grounds.

Ruling on Legality of the Str

Case Syllabus (G.R. No. L-22946)

Facts

A three-year Collective Bargaining Agreement (CBA) was entered into on July 1, 1986 between M. Greenfield, Inc. (B) (the Company) and the local union MSMG, affiliated with the federation ULGWP.
The CBA contained a “Union Security” clause requiring all covered employees to remain union members as a condition of continued employment, and empowered the union to recommend dismissal of members who resigned, failed to pay dues, or violated union by-laws.
On April 17, 1988, a general membership meeting was held. 356 members failed to attend and the local union fined each absentee ₱50 in accordance with its by-laws.
The federation’s Secretary General disapproved the fine; the local union declared general autonomy from ULGWP on July 16, 1988.
The federation placed MSMG under trusteeship, expelled thirty local union officers for alleged disloyalty, and demanded their dismissal under the CBA’s union security clause.
On March 7, 1989, the Company terminated the thirty expelled officers without conducting its own hearing, and barred them from the plant premises.
A member walk-out and a subsequent full-scale strike erupted on March 14, 1989, marked by violence on both sides and preventive suspension of shop stewards and strikers.
Return-to-work notices were sent thrice; only 261 employees responded. The rest were dismissed for alleged abandonment.
Petitioners filed an unfair labor practice complaint (Case No. NCR-00-09-04199-89) before a Labor Arbiter, alleging union busting, illegal suspension and dismissal, discrimination, interference with union activities, threats, intimidation, and violence.
The Labor Arbiter and later the NLRC First Division upheld the Company’s dismissals as valid under the union security clause and declared the strike illegal.

Procedural History

Med-Arbiter orders (Oct 28, 1988; Feb 7, 1989) resolved interpleader over education fund remittances and fines deduction.
Secretary of Labor dismissed intra-union expulsion petition for lack of jurisdiction (A