Case Summary (G.R. No. 201237)
Facts
On June 14, 2000, a union representing employees of MTI filed a petition for a certification election with the Department of Labor and Employment (DOLE), which was granted despite MTI's subsequent motion for reconsideration being denied. Following a sale of MTI's assets to PTI, which included a significant number of buses, MTI announced the termination of their employees. The union claimed this sale aimed to frustrate their right to self-organization and subsequently filed a complaint for illegal dismissal, unfair labor practice, and damages.
LA Ruling
In a Decision dated July 14, 2003, the Labor Arbiter found MTI and the petitioners guilty of unfair labor practices, particularly illegal lockout. The Labor Arbiter concluded that MTI's actions were intended to subvert the employees' rights to unionize and noted that only union members were terminated while others were retained, contradicting claims of financial hardship.
NLRC Proceedings
The petitioners appealed the Labor Arbiter's ruling before the National Labor Relations Commission (NLRC), seeking a reduction of the required bond due to PTI's liquidity issues. The initial appeal faced procedural questions due to the bond posted being less than the monetary award required, leading to dismissals and motions from both parties until the NLRC eventually reinstated the appeal.
NLRC Decision
The NLRC, in a Decision dated January 20, 2006, dismissed the complaint against the petitioners, finding no factual basis for the claim of employer-employee relationship between the respondents and PTI. It asserted that the sale was legitimate and not a sham to evade labor obligations.
CA Ruling
The Court of Appeals annulled the NLRC decision, finding that the NLRC had exercised grave abuse of discretion in allowing the appeal and modifying the Labor Arbiter's original ruling. It ruled that PTI's claimed liquidity problems did not justify the bond reduction.
Central Issue
The pivotal issue for the Supreme Court was whether the Court of Appeals erred in holding that the NLRC's actions constituted grave abuse of discretion when it accepted the appeal from the petitioners.
Court's Ruling
The Supreme Court ruled in favor of the petitioners, stating that the NLRC did not abuse its discretion in granting the appeal. It noted the requirement for a full bond but also recogn
...continue readingCase Syllabus (G.R. No. 201237)
Case Reference
- G.R. No.: 201237
- Date of Decision: September 03, 2014
- Division: First Division
- Justice: Perlas-Bernabe, J.
Background of the Case
- The case is a petition for review on certiorari against the Decision dated November 25, 2011, and Resolution dated March 12, 2012, of the Court of Appeals (CA) in CA-G.R. SP No. 96000.
- The CA reversed and set aside the National Labor Relations Commission (NLRC) Decision dated January 20, 2006, reinstating the Labor Arbiter's Decision dated July 14, 2003, which found MAS Transit, Inc. (MTI) and petitioners guilty of unfair labor practice and illegal lockout.
Facts of the Case
- On June 14, 2000, the Union, representing MTI bus drivers/conductors, filed for a certification election with the Department of Labor and Employment (DOLE), which was granted despite MTI's motion for reconsideration being denied.
- On September 15, 2000, MTI sold its passenger buses and Certificate of Public Convenience (CPC) to Philippine Touristers, Inc. (PTI) for P98,345,834.43, approved by the LTFRB on December 28, 2000.
- MTI notified employees on March 7, 2001, regarding the sale and intention to provide separation benefits, advising them to apply for employment with PTI.
- On March 31, 2001, MTI terminated the employment of Union members, claiming business cessation due to the sale.
- The Union filed a complaint for illegal dismissal and unfair labor practices against MTI and petitioners, alleging that the sale was done