Case Summary (G.R. No. L-10095)
Background of the Dispute
The dispute traces back to a series of demands presented by PHILMAROA on August 28, 1953, including salary standardization, sick and vacation leave, hospitalization provisions, and a closed shop agreement. The respondent shipping companies, however, were unresponsive to these demands, leading PHILMAROA to notify them of impending strikes planned for November 16 and 19, 1953. The President of the Philippines later referred the dispute to the Court of Industrial Relations under Section 10 of Republic Act No. 875.
Court Proceedings and Initial Ruling
After reviewing the labor dispute, the Court of Industrial Relations, under the leadership of Judge Jose S. Bautista, ordered the reinstatement of the striking radio operators. The decision mandated backpay for the operators based on their employment conditions as of August 28, 1953. However, the Court denied several of the union's demands, specifically those related to salary standardization and vacation and sick leaves, citing the financial capabilities of the respondent companies.
Court of Industrial Relations' In-Banc Decision
The ruling was contested by all parties. Judges Lanting, Jimenez, and Yanson participated in a review of the decision. They agreed on reinstating the strikers but declined backpay, maintaining that there was no unreasonable delay or unfair labor practice evident in the responses of the respondent companies to the union demands.
Argument Regarding Unfair Labor Practice
The central issue raised by PHILMAROA was the court's conclusion regarding unfair labor practices. The Union argued that the respondent companies' delays in addressing their demands constituted unfair labor practices. However, the appellate court did not uphold this claim, affirming that the requests were complex and required time for proper deliberation. The court held that the employers must have sufficient time to respond, thereby upholding their legal obligations under the Industrial Peace Act.
Backpay Issue Reviewed
Another emphasis was placed on the denial of backpay to the striking employees. The appellate court found that PHILMAROA had not clearly requested reinstatement or expressed an immediate desire to return to work, leaving such decisions to the court's discretion. In this context, the denial of backpay was justified since the strike was pursued as an economic strategy rather than in response to unfair labor practices.
Interpretation of Section 10 of the Industrial Peace Act
In response to an appeal from Compania Maritima and others, the court addressed the implications of Section 10
...continue readingCase Syllabus (G.R. No. L-10095)
Case Citation
- 102 Phil. 373
- G.R. No. L-10095 and L-10115
- Date of Decision: October 31, 1957
Parties Involved
- Petitioners:
- The Philippine Marine Radio Officers' Association (PHILMAROA)
- Compania Maritima
- Philippine Steam Navigation Company
- Madrigal Shipping Company, Inc.
- Respondents:
- The Court of Industrial Relations
- Various shipping companies including North Camarines Lumber Shipping Co., Pan Oriental Shipping Co., Hijos de F. Escano, Inc., Visayan Transportation Co., Royal Lines, Inc., Carlos A. Gothong Shipping Co., and Bisaya Land Transportation Co.
Background of the Case
- On August 28, 1953, PHILMAROA presented demands to the Association de Navieros, which included:
- Standardization and increase of salaries
- Sick and vacation leave
- Hospitalization
- A closed shop agreement
- The Association de Navieros referred these demands to member companies, with no responses forthcoming.
- PHILMAROA provided notice of strike to the shipping companies on October 17 and 24, 1953.
- A conference was held on October 31, 1953, but the respondent companies claimed they lacked authority to negotiate.
- PHILMAROA declared strikes on November 16 and 19 against Compania Maritima and Philippine Steam Navigati