Union of the Philippines Education Employees v. Philippine Education
REITERATIONFacts
The Antecedents: The Union of the Philippines Education Employees (NLU) filed a case against Philippine Education Co. (PECO) concerning the dismissal of its president, Jacinto Fabroa, and secretary, Juanito Carandang, for alleged defiance of authority and subversive acts, and for engaging in union activities during office hours. The rest of the Union members called a strike due to these dismissals. Procedural History: The Court of Industrial Relations (CIR) found the dismissal of Fabroa and Carandang unwarranted and the strike legal. Consequently, it ordered their reinstatement and the return of other members to work. However, the CIR refused to decree the payment of wages for the period of separation or strike. The Petition: The Union appealed the CIR's order, specifically challenging the denial of back wages for the reinstated officials and striking members.
Issue(s)
Whether the Court of Industrial Relations committed an error in refusing to order the payment of wages to the reinstated officials and striking employees. Whether the dismissal of Jacinto Fabroa and Juanito Carandang was without just cause. Whether the strike was legal and justified the claim for wages during the period of work stoppage.
Ruling
The Supreme Court affirmed the order of the Court of Industrial Relations, holding that the denial of back wages to the reinstated officials and striking employees was not an error. The Court ruled that the payment of wages during suspension or dismissal without just cause, or during a strike, is discretionary and not an absolute right.
Ratio Decidendi
On the issue of payment of wages to dismissed/striking employees: The Court reiterated that Paragraph 2, Section 19 of Commonwealth Act No. 103, as amended, which allows the CIR to direct the payment of salary or wage during suspension or dismissal without just cause, uses the word "may" and not "shall." This indicates that the matter is left to the sound discretion of the court, to be determined based on justice and equity, without regard to technicalities. The Court found that the CIR did not abuse its discretion in denying back wages, considering the circumstances surrounding the dismissals and the strike, including the probability that the dismissals were not entirely devoid of basis and that the employees' actions bordered on unfair labor practices. The Court also noted that the strike was deemed voluntary and unnecessary. On the legality of the strike and claim for wages: The Court held that since the strike was launched solely due to the dismissal of Fabroa and Carandang, the striking employees' right to backpay could not be greater than that of the dismissed officials. The Court found no urgent need for a strike, as Fabroa and Carandang were paid a month's salary and their case was to be taken up with the CIR. The Court also considered evidence of violence and intimidation during the strike, which, although not reported to the police, cast doubt on the strikers' conduct. The Court concluded that the strike was voluntarily initiated and unnecessary, thus justifying the denial of remuneration for the period of work stoppage. On the dismissal of Fabroa and Carandang: While the CIR found the dismissal unwarranted, the Supreme Court noted that the evidence presented by the company suggested acts bordering on insubordination and defiance of authority. The Court observed that the CIR's exoneration was based on doubts and a benefit of the doubt given to the employees, rather than a clear conviction of innocence. The Court also highlighted misstatements made by Fabroa and Carandang, such as misleading co-employees about a pending case and attempting to obstruct the company's legitimate efforts to explain its financial situation. These actions, in the Court's view, demonstrated bad faith and warranted the CIR's reluctance to award back wages.
Main Doctrine
The payment of wages to employees suspended or dismissed without just cause, or during a strike, is discretionary and not a matter of absolute right, to be determined by the Court of Industrial Relations based on justice and equity, considering the evidence and circumstances.