G.R. No. 88710-13 - Union of Filipro Employees vs. Nestle Philippines, Inc.

Case Summary (G.R. No. 88710-13)

Relevant Legal Framework

The applicable law in this case is primarily derived from the 1987 Philippine Constitution, along with various provisions of the Labor Code of the Philippines. Key articles considered include Article 263 and Article 264, which govern the conduct of strikes, collective bargaining agreements (CBAs), and the circumstances under which a strike is deemed illegal.

Background of the Dispute

The initial conflict began when UFE filed a notice of strike on November 14, 1985, against Filipro (now Nestle), citing multiple grievances, including unfair labor practices. In response, the Minister of Labor issued an order assuming jurisdiction over the dispute, which directed the union to refrain from strikes and return to work, asserting that the strike was illegal due to this order. The union's leaders ignored this directive, prompting Nestle to seek legal recourse through the NLRC against the union for violating the law.

Legal Proceedings and NLRC's Decisions

The NLRC affirmed earlier rulings by Labor Arbiters that declared the strikes illegal and found the UFE guilty of committing unfair labor practices. This decision indicated that the union had violated the "no strike/no lockout" provisions in its collective bargaining agreement and had also failed to exhaust all grievances through stipulated channels prior to initiating strikes.

Petitioner's Arguments

UFE contended that the NLRC acted with grave abuse of discretion by reaffirming the illegality of the strikes. They argued that the provisions enabling compulsory arbitration (Articles 263 and 264) were no longer valid under the 1987 Constitution and that their motives were justified based on labor rights. They further asserted that the union and its members did not commit acts serious enough to warrant the claim of illegal strikes.

Responses and Legal Conclusions

The court maintained that the NLRC was correct in its assertion that Articles 263 and 264 of the Labor Code were still applicable, given that no law had been passed to repeal these provisions specifically. The court emphasized the significance of the return-to-work orders issued by the Minister of Labor, indicating that they must be complied with irrespective of any claims made by the workers about the legality of their strike.

Findings of Illegal Actions

The court outlined that the activities conducted by UFE members breached labor laws due to acts of coercion and intimidation during the strike, which resulted in their loss of employment status. It specified that the strikes were not only illegal due to the violation of established laws and orders, but also for disregarding the grievance me