Case Summary (G.R. No. 141296)
Background Facts
The grievance arose when Francisco San Jose filed a charge for unfair labor practices against the respondent on October 23, 1958. Following this, on November 29, 1958, and December 11, 1958, the company's manager, Chue Yiong, reportedly threatened Lazaro Peralta, the union president, with Apolonio’s dismissal if Francisco did not withdraw his complaint. Apolonio was subsequently dismissed on January 24, 1959, prompting the union to file a complaint citing violations pertaining to his rights under the collective bargaining agreement.
Allegations and Court Findings
The Court of Industrial Relations dismissed the union’s complaint, asserting that evidence presented did not demonstrate unlawful interference or discrimination against Apolonio regarding his right to employment. While the Court acknowledged that Apolonio’s dismissal was due to his brother's legal actions, it concluded that this did not qualify as an unfair labor practice under Section 4(a)(5) of Republic Act No. 875, which specifically shields employees from retaliation for their own complaints, not those of relatives.
Jurisdiction and Interpretation Issues
The Court's conclusion that it lacked jurisdiction to entertain the union's claim has been found untenable. The reasoning stemming from Section 4(a)(5) focuses solely on direct actions against the complainant, undermining the fundamental protections against retaliatory actions impacting family members of employees engaged in legal labor activities. The overarching purpose of the labor legislation is to provide unimpeded freedom for employees to organize and to raise grievances without fear of repercussion either directly or indirectly.
Legal Precedents and Application
The dismissal of Apolonio as a result of his brother's charges parallels established labor law principles where retaliatory actions against family members constitute an unfair labor practice. Referenced cases such as Quidnick Dye Works and Mansfield Mills illustrate that discriminatory practices against relatives of complainants are action
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Case Overview
- The case involves an appeal by the Philippine American Cigar & Cigarette Workers Independent Union (NLU) from a decision of the Court of Industrial Relations.
- The initial complaint was for unfair labor practice concerning the dismissal of Apolonio San Jose, the brother of Francisco San Jose, who had filed an earlier unfair labor practice charge against the respondent company.
Background Facts
- On October 23, 1958, Francisco San Jose, a member of the complainant union and regular worker at the respondent company, filed a charge for unfair labor practice, which was still pending at the time of the events.
- The company's manager, Chue Yiong, summoned union president Lazaro Peralta on November 29 and December 11, 1958, threatening that Apolonio San Jose would be dismissed if Francisco did not withdraw his charge.
- Apolonio was dismissed on January 24, 1959, allegedly without just cause, with claims of gross violation of the collective bargaining agreement.
Court of Industrial Relations Findings
- The Court found that the allegations of unfair labor practice were substantiated by witnesses but concluded they did not