Case Summary (G.R. No. 68619)
Factual Background
The petitioners filed a complaint alleging illegal dismissal, unfair labor practice, and moral damages against their employer, Shellwood Industries, and union officials. On February 5, 1981, a compromise agreement was reached where Shellwood agreed to provide P20,000 in financial assistance to the union in exchange for withdrawing a previous case. Following internal issues within the union, including the resignation of Concepcion Nuguid, tensions escalated, leading the union to expel the complainants and request their dismissal from the company, resulting in their termination on August 16, 1982.
Labor Arbiter's Decision
On October 28, 1983, Labor Arbiter Pelagio A. Carpio ruled in favor of the petitioners, ordering their reinstatement to their prior positions without back wages and forcing the company to provide financial assistance equivalent to six months of their salaries. However, the Arbiter dismissed the complaints for unfair labor practice and moral damages for lack of merit.
NLRC's Ruling
Upon appeal, the NLRC affirmed the ruling of reinstatement but deleted the order for financial assistance, citing a lack of legal and factual basis. They determined that the company acted in good faith upon the request of the union president and that the union had the authority to request the termination of the complainants' employment. Therefore, the NLRC concluded that the company did not participate in the illegal dismissal and could not be held liable for financial assistance.
Petitioners' Argument
The petitioners argued that the company had full awareness of Nuguid's resignation and her lack of authority to act on behalf of the union, thereby asserting that the company was liable for their dismissal and the financial assistance awarded by the Labor Arbiter. They contended that the company's negligence in this regard warranted compensation for their suffering and damages.
Respondents' Justification
Respondents countered that there was no legal basis for the financial assistance since the Labor Arbiter’s order for reinstatement was inconsistent with an award of such assistance. They asserted that the company had acted in good faith in complying with the union’s requests and emphasized that the collective bargaining agreement (CBA) stipulated the company's obligation to dismiss any employee who had been resigned or expelled from the union.
Legal Findings and Con
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Background of the Case
- The petitioners, a group of ten complainants, include Lourdes Soriano, Dorotea Tamaca, Asuncion Vera, Marciana De Los Reyes, Evelyn Dacallos, Yolanda Villanueva, Antonio Dabe, Zoraida Delantar, Anita Dana, and Anacurita Navarro.
- They filed a complaint against Shellwood Industries Philippines, Inc., its president Ramon Panique, and Concepcion Nuguid, the former president of the union, for illegal dismissal, unfair labor practice, and moral damages.
- On February 5, 1981, a compromise agreement was reached between the union and the company, where the company agreed to provide financial assistance of P20,000 in exchange for the union's withdrawal of a previous case.
Events Leading to Dismissal
- Following the compromise agreement, there was curiosity about the disposition of the P20,000.
- During a general meeting on April 4, 1982, when questioned about the funds, Concepcion Nuguid unexpectedly resigned, and her resignation was accepted on April 5, 1982.
- The union became dormant for over three months until a meeting on July 13, 1982, where new resolutions were passed to affiliate the union with a federation and form a steering committee.
- On July 29, 1982, a resolution was passed to expel the complainants from the union and requested the company to terminate their services.
- The complainants were dismissed on August 16, 1982, at the request of the union led by Nuguid.
Labor Arbiter’s Decision
- On October 28, 1983, Labor Arbiter Pelagio A. Carpio ordered the reinstatement