Case Summary (G.R. No. 170830)
Factual Background
During the negotiation for a collective bargaining agreement set to expire on December 31, 1994, PHIMCO and PILA reached a deadlock. PILA filed a Notice of Strike with the National Conciliation and Mediation Board (NCMB) on March 9, 1995, initiating a process that led to a strike vote and subsequent strike beginning on April 21, 1995. PHIMCO, concerned about the strike's impact, sought a temporary restraining order against the strikers. After dismissing 36 union members for alleged illegal acts during the strike, PILA filed a complaint for unfair labor practice with the National Labor Relations Commission (NLRC).
NLRC Ruling
The NLRC initially sided with PILA, ruling that the actions of the strikers did not constitute an illegal blockade and dismissing the charges against them. On March 2, 1999, the NLRC affirmed the reinstatement of the dismissed workers and awarded them back wages, ruling that their picketing was lawful.
Court of Appeals Ruling
PHIMCO filed a petition for certiorari in the Court of Appeals (CA), which was subsequently dismissed. The CA affirmed the NLRC’s findings that the strike had been conducted peacefully and not obstructively, thereby rejecting PHIMCO's claims.
The Petition and Respondents' Position
PHIMCO contended that the strike was illegal, highlighting violations of Article 264(e) of the Labor Code, including blocking access to the workplace. Respondents argued that the issues raised were factual and within the purview of the labor courts to determine.
Core Issue
The essential legal question was whether the CA correctly ruled that the NLRC did not commit grave abuse of discretion in determining that the strike was lawful.
Our Ruling on the Strike’s Validity
The Supreme Court found in favor of PHIMCO, declaring the strike illegal. It specified that for a strike to be considered valid, it must adhere to the procedural prerequisites outlined in Article 263 of the Labor Code, which the respondents satisfied. However, despite procedural compliance, the strike was rendered illegal due to the means employed—specifically, that the picketing obstructed ingress and egress to the company premises, thus violating Article 264(e).
Evidence of Illegal Picketing
The evidence, including photographs and affidavits, substantiated PHIMCO’s claims that the union's actions effectively blocked access to the workplace. Testimonies indicated that managers and employees were consistently denied entry, reinforcing the conclusion that the strike was not conducted in a lawful manner as required by labor laws.
Intimidation and Blocking of Access
The Court elaborated that intimidation could manifest not only through overt threats but also through the creation of an atmosphere that deters non-striking employees from crossing the picket line. The testimony and evidence revealed that respondents engaged in actions that unlawfully prevented entry and exit from company premises, constituting a breach of labor regulations.
Liabilities of Union Officers and Members
The Supreme Court underscored that union officers who knowingly participate in an illegal strike could be dismissed, as per Article 264(a) of the Labor Code. The evidence identified specific union officials as having participated in the illegal acts that led to the obstruction of access, which warranted dismissal.
Due Process Violations by PHIMCO
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Case Overview
- Court: Supreme Court of the Philippines
- Division: Third Division
- G.R. No.: 170830
- Date of Decision: August 11, 2010
- Petitioner: Phimco Industries, Inc. (PHIMCO)
- Respondents: Phimco Industries Labor Association (PILA) and various individuals in their capacity as officers and members of PILA.
Procedural History
- PHIMCO filed a petition for review on certiorari to reverse the Court of Appeals' (CA) decision dated February 10, 2004, and the resolution dated December 12, 2005.
- The CA's decision dismissed PHIMCO's petition for certiorari that challenged the National Labor Relations Commission (NLRC) ruling on the illegal strike and unfair labor practice cases.
Factual Background
- PHIMCO is a corporation that produces matches, located in Sta. Ana, Manila.
- PILA is the authorized bargaining representative for PHIMCO's daily-paid workers.
- A deadlock arose in negotiations for a new collective bargaining agreement before the expiration of the previous contract on December 31, 1994.
- PILA filed a Notice of Strike on March 9, 1995, due to the deadlock, followed by a strike vote on March 16, 1995, resulting in a majority vote for the strike.
- On April 21, 1995, PILA commenced the strike.
- PHIMCO sought a preliminary injunction and temporary restraining order to prevent strikers from blocking non-striking employees' access.
- The NLRC issued a temporary restraining order, leading to further developments including dismissals of certain union members on June 26, 1995.
- PILA filed a complaint for unfair labor practice and illegal dismissal, while PHIMCO counter-claimed seeking to declare the strike illegal.
NLRC Ruling
- The NLRC ruled in favor of PILA, finding that the strike was conducted lawfully, and dismissed PHIMCO's motion for reconsideration regarding the illegal strike.
- The NLRC ordered the reinstatement of the dismissed workers wi