Case Summary (G.R. No. 140992)
Factual Background
Following negotiations over economic provisions of the collective bargaining agreement (CBA) that stalled, the petitioner union filed a notice of strike on March 1, 1994, citing a collective bargaining deadlock. In response, Sulpicio Lines, Inc. petitioned the Department of Labor and Employment (DOLE) to take jurisdiction over the dispute. The Labor Secretary issued an order on March 23, 1994, enjoining any strike or lockout. On May 20, 1994, the petitioners conducted a work stoppage which they labeled a strike after alleging unfair labor practices by the respondent.
Labor Secretary’s Intervention
Former Labor Secretary Nieves R. Confesor intervened by directing the striking employees to return to work and certifying the dispute to the National Labor Relations Commission (NLRC) for compulsory arbitration, docketed as NLRC Case No. CC-0083-94. Concurrently, the respondent filed a complaint for illegal strike and clearance for termination against union officers.
NLRC Findings
On September 29, 1995, the NLRC ruled the May 20, 1994 work stoppage illegal, noting that the union’s action contravened the Labor Secretary’s assumption order. The resolution allowed the respondent to terminate the employment of specific union officers involved in the illegal strike and dismissed the union’s complaint against the respondent for lack of merit.
Court of Appeals Decision
The petitioners sought reconsideration, which was denied by the NLRC on January 15, 1996. Their subsequent petition for certiorari was referred to the Court of Appeals, which affirmed the NLRC's decision on May 28, 1999. The appellate court confirmed the NLRC's jurisdiction and upheld the legality of the terminations based on the illegal strike participation by the union officers.
Key Issues for Determination
The core issue considered by the Supreme Court was whether the petitioners' actions constituted an illegal strike. The assessment focused on compliance with procedural requirements outlined in Articles 263 and 264 of the Labor Code, particularly the necessary notice period and the requirement for a strike vote.
Procedural Requirements and Non-compliance
The Labor Code mandates specific procedural steps before initiating a strike, including a notice of at least 30 days for bargaining deadlocks and 15 days for unfair labor practices. Evidence indicated the petitioners failed to observe the seven-day notice requirement mandated after a strike vote. This procedural lapse rendered their strike illegal under the law.
Union's Defense Against Illegality
The petitioners argued their actions were a legitimate response to perceived unfair labor practices by the respondent. However, the Supreme Court found no substantial evidence related to these allegations. The burden rested on the union to prove any charges of unfair labor practices, which they failed to substantiate.
Definition and Nature of a Strike
The Supreme Court reiterated the definition of a strike under the Labor Code, confirming that a collective work stoppage, even for one day, amounts to a strike if it results from a labor dispute. The collective action by the union members on May 20, 1994, met the criteria for a strike, thus reinforcing the illegality of their actions due to non-compliance with the requisite procedural steps.
Conclusion on Employment Status
Reflecting on
...continue readingCase Syllabus (G.R. No. 140992)
Background of the Case
- This case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- The petitioners, Samahang Manggagawa sa Sulpicio Lines, Inc., and its members, contest the decision and resolution of the Court of Appeals dated May 28, 1999, and November 25, 1999, respectively.
- The primary issue at hand is whether the strike conducted by the petitioners on May 20, 1994, was legal or illegal.
Factual Antecedents
- On February 5, 1991, a Collective Bargaining Agreement (CBA) was executed between Sulpicio Lines, Inc. (respondent) and the petitioner union, valid from October 17, 1990, to October 16, 1995.
- Negotiations for economic provisions of the CBA began on December 15, 1993, but reached a stalemate.
- Petitioner filed a notice of strike on March 1, 1994, due to the bargaining deadlock, while the respondent sought the intervention of the Department of Labor and Employment (DOLE).
- An Order was issued by the former Labor Secretary on March 23, 1994, assuming jurisdiction and enjoining any strike or lockout.
Events Leading to the Strike
- On May 20, 1994, the petitioner filed a second notice of strike citing unfair labor practices by the respondent, which included allegations of union busting.
- The union conducted a strike vote, leading to 167 members not reporting for work and gathering at Pier 12, North Harbor, Manila.
- In response, the Labor Secre