Case Summary (G.R. No. 89920)
Key Dates
- June 19, 1989: Termination of faculty members by UST.
- July 5, 1989: Faculty union filed a complaint for illegal dismissal and unfair labor practices.
- July 11, 1989: Secretary of Labor and Employment issued an order to temporarily suspend termination effects.
- July 18, 1989: Secretary modified the previous order and certified the dispute to the NLRC.
- September 6, 1989: The NLRC issued a resolution on the case.
- October 25, 1989: The Court issued a temporary restraining order against the NLRC resolution.
Applicable Law
The primary legal framework governing this case is derived from Article 263(g) of the Labor Code, as amended by Republic Act No. 6715. This provision addresses labor disputes that affect industries vital to the national interest and specifies the processes involved when such disputes arise.
Facts of the Case
The controversy began with the dismissal of sixteen faculty members on allegations of grave misconduct related to a published document targeting a university official. In retaliation to the mass dismissal, faculty members engaged in mass absenteeism, disrupting classes. Following the filing of a complaint by the faculty union, the Secretary of Labor intervened and temporarily suspended the termination effects, directing UST to readmit the faculty members under previous conditions. Despite these directives, UST provided "substantially equivalent academic assignments" as opposed to full reinstatement. The NLRC later intervened to ensure compliance with the Secretary's orders, but UST continued with its amended assignment approach, prompting allegations of non-compliance and union-busting.
Legal Reasoning
The Supreme Court evaluated UST's compliance with the Labor Secretary's directives, highlighting that actual reinstatement was mandated. The rationale stems from the urgent need to maintain the status quo during labor disputes affecting the educational system. The Court determined that offering substantially equivalent academic assignments was not adequate under the circumstances, as it did not fulfill the requirement for actual reinstatement, which necessitated returning faculty members to their original teaching loads.
Conclusion and Court’s Orders
The petition by UST was ultimately dismissed. The NLRC's resolution mandating UST to t
...continue readingCase Syllabus (G.R. No. 89920)
Overview of the Case
- The case involves the University of Santo Tomas (UST) petitioning against the National Labor Relations Commission (NLRC) and the UST Faculty Union regarding the dismissal of sixteen union officials.
- The central issue is whether UST can grant substantially equivalent academic assignments to the dismissed faculty members pending resolution of the labor dispute, instead of their actual reinstatement.
Background Information
- On June 19, 1989, UST terminated the employment of sixteen union officers based on allegations of grave misconduct.
- Following the dismissals, faculty members protested by staging mass leaves, disrupting classes.
- The UST Faculty Union filed a complaint for illegal dismissal and unfair labor practices with the Department of Labor and Employment on July 5, 1989.
Sequence of Events
- July 7, 1989: The labor arbiter certified the dispute to the Secretary of Labor for possible suspension of termination effects.
- July 11, 1989: Secretary Franklin Drilon issued an order suspending the effects of the termination and ordering the reinstatement of the dismissed faculty members.
- July 18, 1989: Following UST's motion for reconsideration, the Secretary modified the order, certifying the dispute to the NLRC and reiterating the readmission order.
- July 27, 1989: The Secretary affirmed the previous orders, directing the NLRC to ensure compliance.
- August 11, 1989: The NLRC called for a conference regarding the implementation of the readmission orders.
- September 6, 1989: The NLRC issued a resolution directing UST t