Case Summary (G.R. No. 159402)
Background of the Dispute
The Petitioner seeks a judicial review of the Court of Industrial Relations' decision rendered on December 20, 1938, which the Petitioner contends is contrary to law, the weight of evidence, and violates its rights. The Petitioner raised several issues: the Court’s failure to hold the Manila Gas Corporation in contempt for employing strikebreakers, to permit strikers to return to work under prior conditions, and to order the strikers back to work given the ongoing nature of the dispute.
Employment of Strikebreakers
The central allegation by the Petitioner is that the Manila Gas Corporation violated section 19 of Commonwealth Act No. 103, which prohibits the hiring of strikebreakers during a labor dispute without court permission. However, an amendment to this provision allows for exemptions for public utilities. The Court determined that as Manila Gas Corporation functions as a public utility, it was not in violation of this prohibition when it employed strikebreakers during the strike. As such, the Court of Industrial Relations did not err in finding no contempt.
Just Causes for Dismissal
The Court also evaluated whether the Industrial Relations Court correctly refrained from ordering the Manila Gas Corporation to reinstate the strikers. Evidence showed that the strikers engaged in acts of sabotage against the company—such actions constituted just cause for dismissal. The Court referenced Article 1586 of the Civil Code, which allows for dismissal without cause under specific conditions, and concluded that the strikers’ actions significantly breached their implied contractual obligations, allowing the employer to terminate their employment based on these breaches.
Nature of the Strike
The strike was labeled illegal due to the violent and sabotage actions undertaken by the strikers, which hindered the company's operation and created public safety risks. Thus, the Court assessed that the strikers had forfeited their right to return to work due to the unlawful nature of their strike actions, ultimately reinforcing the company's right to engage other workers in compliance with public service obligations.
Impact of Employment Contract
Regarding a separate contract entered into between the Manila Gas Corporation and another union, it was established that the petitioners' strike and their noncompliance with the contract negated any rights associated with it. Despite the at
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Case Overview
- The case involves an appeal by the National Labor Union, Inc. against the Court of Industrial Relations and Manila Gas Corporation, seeking to declare the court's previous decisions null and void.
- The petitioner argues that the decisions were contrary to law, the weight of evidence, and violated the petitioner's rights.
- The specific errors alleged include failure to find the respondent company in contempt, failure to order the company to permit strikers to return to work, and failure to compel the strikers to return to work.
Legal Background
- The petitioner claims that the Manila Gas Corporation employed strike breakers within fifteen days of the strike's declaration, violating Commonwealth Act No. 103, particularly section 19, which prohibits such employment during a labor dispute.
- An amendment to section 19, via Commonwealth Act No. 355, exempts employers in public service or businesses with public interest from this prohibition.
- The Court of Industrial Relations found that the Manila Gas Corporation, as a public utility, was exempt from the prohibition and did not commit contempt by employing strike breakers.
Acts of Sabotage
- The Court of Industrial Relations established that the strikers committed acts of sabotage, including:
- Introducing wate