Case Summary (G.R. No. 232687)
Facts of the Case
Respondent was employed at Slord Development Corporation under a collective bargaining agreement with the Nagkakaisang Lakas ng Manggagawa-Katipunan (NLM-Katipunan). This agreement included a union security clause that mandated union membership as a condition for continued employment. In December 2013, respondent allegedly solicited signatures from fellow employees to form a new union, which led to his expulsion from NLM-Katipunan for disloyalty. Following this expulsion, NLM-Katipunan demanded the termination of respondent's employment on March 16, 2014, resulting in his dismissal on March 19, 2014. Respondent subsequently filed a complaint for illegal dismissal and unfair labor practices against petitioner.
Labor Arbiter's Ruling
The Labor Arbiter dismissed respondent's case, affirming that the dismissal was lawful due to the closed shop provision in the CBA. The Arbiter ruled that petitioner was obliged to terminate respondent's employment following his expulsion from the union for organizing a rival union. Respondent appealed this decision.
Ruling of the National Labor Relations Commission
The National Labor Relations Commission (NLRC) similarly upheld the Labor Arbiter's decision but modified it to include an award of nominal damages of ₱10,000 for the violation of procedural due process, as respondent was not given a sufficient opportunity to defend himself during the expulsion process. Respondent's motion for reconsideration was denied.
Court of Appeals Decision
The Court of Appeals granted respondent’s petition for certiorari, ruling that his dismissal was illegal. It ordered petitioner to reinstate respondent and to pay him full back wages and allowances up to reinstatement, along with attorney's fees. The CA found that there was insufficient evidence supporting the justification for respondent's expulsion and that his rights to procedural due process were violated.
Issue for Resolution
The central issue was whether the Court of Appeals correctly determined that respondent was illegally dismissed by his employer.
Supreme Court’s Ruling
The Supreme Court ruled in favor of petitioner, stating that the CA had erred in attributing grave abuse of discretion to the NLRC. The Court reaffirmed that just cause for termination under the union security clause existed due to respondent's actions in soliciting signatures for a rival union outside the permissible period. The union security clause was deemed valid and reflective of the rights established under the Labor Code.
Requirements for Termination Under Union Security Clause
The Court specified that valid termination under the union security clause requires:
- Applicability of the clause.
- A request from the union for enforcement.
- Sufficient evidence supporting the union's decision to expel the employee.
In this instance, all three requirements were satisfied.
Procedural Due Process
Despite affirming the legality of the dismissal based on just cause, the Supreme Cou
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Background of the Case
- Parties Involved: Slord Development Corporation (Petitioner) and Benerando M. Noya (Respondent).
- Court: The Supreme Court of the Philippines.
- Case Reference: G.R. No. 232687.
- Date of Decision: February 04, 2019.
- Previous Rulings: The Court of Appeals (CA) in CA-G.R. SP No. 138705 reversed the National Labor Relations Commission (NLRC) ruling, leading to the Supreme Court petition.
Facts of the Case
- Employment Details: Respondent was hired as a welder on September 9, 2008, by the petitioner, a corporation engaged in manufacturing sardines and canned goods.
- Collective Bargaining Agreement (CBA): A CBA was effective from April 14, 2009, to April 15, 2014, with provisions including a union security clause.
- Union Security Clause: The clause mandated that employees must join and remain members of the union (NLM-Katipunan) to maintain employment.
- Disloyalty Allegations: In December 2013, Respondent allegedly solicited signatures to form a new union, resulting in expulsion proceedings initiated by NLM-Katipunan for disloyalty.
- Formation of Rival Union: Respondent registered a new union, Bantay Manggagawa sa SLORD Development Corporation (BMSDC), on February 20, 2014.
- Expulsion Process: NLM-Katipunan expelled Respondent on February 27, 2014, after he failed to participate in the hearings regarding his expulsion.
- Termination: Petitioner terminated Respondent's employment on March 19, 2014, following a demand