Manila Oriental Sawmill Co. v. National Labor Union
REITERATIONFacts
The Antecedents: On May 4, 1950, the United Employees Welfare Association (UEWA), a union with members among petitioner's employees, entered into a one-year agreement on working conditions with petitioner Manila Oriental Sawmill Co. (MOSSC). On August 14, 1950, thirty-six of UEWA's thirty-seven members resigned and joined the local chapter of respondent National Labor Union (NLU). On August 15, 1950, NLU presented seven demands to MOSSC. MOSSC, through counsel, responded that the laborers were affiliated with UEWA. NLU reiterated its demands on August 22, 1950. MOSSC's counsel replied that it could not recognize NLU's local chapter until the May 4, 1950 agreement was declared null and void by the Court of Industrial Relations (CIR). Procedural History: On August 28, 1950, NLU members struck. On August 31, 1950, MOSSC filed a petition with the CIR to declare the strike illegal. On September 8, 1950, the CIR denied MOSSC's prayer and set the case for hearing on NLU's demands. MOSSC filed a motion for reconsideration, which was denied by the CIR en banc on November 14, 1950. MOSSC then filed the present petition for review. The Petition: MOSSC claims the CIR's order is void for refusing to declare the strike illegal despite the existence of a valid agreement between the employees' former union and MOSSC, thereby violating the constitutional precept of freedom of contract.
Issue(s)
Whether a strike is legal when staged by employees who switched union affiliation for the purpose of disregarding a valid and subsisting collective bargaining agreement.
Ruling
The Supreme Court reversed the order of the respondent court, declaring the strike illegal and denying the prayer to set the case for hearing on the demands of the respondent union.
Ratio Decidendi
On Issue 1: The Court ruled that the strike was illegal because its manifest purpose was to circumvent a valid contract. The Court noted that the NLU chapter consisted almost entirely of the same individuals who were members of the UEWA when the May 4, 1950 agreement was signed. This move was characterized as a 'subterfuge' to present demands that differed from those previously agreed upon. The Court held that allowing such a move would result in the subversion of a contract freely entered into without any justifiable reason. Relying on the principle of freedom of contract and good faith, the Court stated that labor organizations lose their legitimate purpose when used to undermine existing valid commitments. Furthermore, the Court adopted the reasoning in Triburo Coach Corp., stating that employees' obligations may not be repudiated simply by the process of changing representatives. The manifest object of labor laws is to prevent industrial strife through collective agreements, and permitting the substitution of bargaining agencies during the life of a contract to escape obligations would defeat this purpose.
Main Doctrine
A strike staged by members of a labor union to circumvent a valid and subsisting collective bargaining agreement entered into by the same employees with their employer is illegal, as it constitutes a subversion of contractual obligations and a derogation of the principle of freedom of contract and good faith.