Luzon Marine Department Union v. Roldan
REITERATIONFacts
1. The Antecedents: The petitioner, Luzon Marine Department Union, presented twelve demands to Luzon Stevedoring Co., Inc., including recognition, collective bargaining, closed-shop, and check-off rights. The Union de Obreros Estivadores de Filipinas (U.O.E.F.), which had a prior agreement with the company recognizing it as the sole bargaining agent, intervened, arguing that the petitioner's demands would violate their existing agreement. The U.O.E.F. moved to dismiss the petitioner's case, questioning its membership size. 2. Procedural History: The petitioner filed a case in the Court of Industrial Relations (CIR) seeking compliance with its demands. The U.O.E.F. intervened and moved for dismissal based on jurisdiction. After hearings, the CIR denied the motion to dismiss. Subsequently, 65 members of the petitioner failed to report for work, leading to their replacement by U.O.E.F. members. The petitioner then filed a petition alleging a strike due to the company's refusal to negotiate and threats of dismissal, seeking a restraining order against strike breakers. The CIR initially ordered the strikers to return to work and be reinstated, but upon reconsideration by the court en banc, this order was set aside, declaring the strike illegal. 3. The Petition: This petition for certiorari seeks to review the CIR's resolution declaring the strike illegal. The petitioner argues that the strike was lawful, motivated by the desire to demonstrate their membership strength (over thirty members) and by threats of dismissal from an individual named Alejo Villanueva. The Supreme Court, however, affirmed the CIR's resolution, holding that the strike's purpose was either trivial, unreasonable, or an unwarranted interference with the judicial process, and that strikes are generally viewed unfavorably due to their disruptive effects on social order and public interest, especially when alternative legal processes are available.
Issue(s)
Whether the strike declared by the petitioner was legal and justified. Whether the CIR erred in setting aside the order directing the strikers to return to work and be reinstated.
Ruling
The Supreme Court affirmed the resolution of the Court of Industrial Relations setting aside the order directing the strikers to return to work and be reinstated, and declared the strike illegal.
Ratio Decidendi
On the legality and justification of the strike: The Court held that while Commonwealth Act No. 103 provides that employees are inhibited from striking only when enjoined by the Court, the legality or illegality of a strike in cases not falling within this prohibition depends on the purpose for which it is maintained and the means employed. The Court cited previous rulings in Rex Taxicab Company vs. Court of Industrial Relations and Manila Trading and Supply Company vs. Philippine Labor Union to establish that employees have an obligation not to strike or walk out if they expect to be continued in their service under existing terms. The Court further referenced National Labor Union, Inc. vs. Philippine Match Company, where a strike motivated by an unreasonable demand for the dismissal of a foreman was declared illegal. The Court emphasized that strikes are coercive and disruptive to the social order and public interests, and laborers who resort to them outside of statutory means must accept the attendant risks. The CIR found that the strike was motivated by the union members' impatience and doubt regarding the court's decision, and the assertion by the company that the petitioner lacked sufficient members. The Court concluded that this purpose was an unwarranted interference with the legal process and tended to destroy public confidence in the machinery for resolving industrial disputes. The alleged threat of dismissal by Alejo Villanueva, an officer of the intervenor union and not the company, was deemed trivial and puerile, especially since the petitioner knew that dismissals during the pendency of a dispute required court permission. Therefore, the Court found the strike illegal and unjustified. On the CIR's resolution: The Court found that the CIR correctly applied the settled doctrines of the Supreme Court regarding the illegality of strikes based on their purpose and the means employed. The Court reiterated its stance that the law does not favor strikes due to their disruptive effects and has established agencies to prevent them. While not expressly banning strikes except when enjoined, the law will not sanction strikes for trivial, unjust, or unreasonable purposes, or those carried out through unlawful means. The Court reaffirmed that laborers who resort to strikes instead of legal processes do so at their own risk, and if the strike is found unjustified, they will suffer adverse consequences. Consequently, the CIR's resolution setting aside the order for reinstatement was sustained.
Main Doctrine
A strike declared during the pendency of an industrial dispute before the Court of Industrial Relations, even if not explicitly enjoined by the Court, may be declared illegal if its purpose is trivial, unreasonable, or unjust, or if it is carried out through unlawful means. Laborers who resort to a strike instead of first utilizing legal processes do so at their own risk.