Liberal Labor Union v. Philippine Can Company
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a reduction in wages by the Philippine Can Company for seven of its laborers. The Liberal Labor Union protested this reduction, but their attempts to resolve the issue internally were met with resistance and denial by the company's management. This led to a labor dispute that was subsequently brought before the Court of Industrial Relations. 2. Procedural History: Following the filing of a labor dispute (Case No. 229-V) in the Court of Industrial Relations, the Liberal Labor Union and the Philippine Can Company entered into a collective bargaining agreement on February 26, 1949. Initially, a judge of the Court of Industrial Relations held the strike legal, but this decision was reversed upon a motion for reconsideration, deeming the strike illegal. This reversal forms the basis of the current petition for review. 3. The Petition: The Liberal Labor Union filed this petition for review of the Court of Industrial Relations' resolution that declared their strike of March 14, 1949, illegal. The union argues that they were justified in striking because the company failed to designate representatives to the grievance committee, thereby preventing the union from utilizing the agreed-upon dispute resolution procedure. They contend that the company's failure to comply with the agreement relieved the union of its obligation to exhaust all procedural steps before striking.
Issue(s)
Whether the strike staged by the union was legal despite the company's failure to appoint its representatives to the grievance committee as required by the Collective Bargaining Agreement. Whether the use of coercion, intimidation, and obscene language during the strike affects its legality.
Ruling
The resolution of the Court of Industrial Relations declaring the strike illegal is affirmed. The petition is denied.
Ratio Decidendi
On Issue 1: The Court held that the strike was illegal because the union failed to exhaust the graduated grievance procedure stipulated in the Collective Bargaining Agreement. While it was true that the management failed to nominate its representatives to the grievance committee (the first step), this failure did not authorize the union to declare an outright strike. The Court reasoned that the union had the duty to exhaust all available means within its reach, which included the second step (conference of top officials) and the third step (submission to the Court of Industrial Relations). The primary purpose of such procedures is to prevent strikes and maintain industrial peace, and they must be strictly adhered to if their ends are to be achieved. By ignoring the judicial remedy provided in the contract and jumping straight to a strike, the union violated the spirit of compulsory arbitration. Therefore, the union's failure to seek the intervention of the CIR before striking constituted a material breach of the CBA, rendering the strike illegal. On Issue 2: The Court further ruled that the strike was illegal due to the proven facts that top officials and members of the union employed coercion, force, intimidation, and physical injuries during the strike. The evidence showed that the strikers used sabotage and obscene language or epithets to prevent other willing laborers from going to work. The Court emphasized that a strike held under such circumstances cannot be justified in a regime of law, as it would encourage abuses and terrorism. Quoting Greater City Masters Plumbers Association vs. Kahme, the Court noted that a labor philosophy based on 'might is right' is a regression that leads only to disorder and class hatred. Consequently, the violent and intimidatory nature of the strike provided an independent ground for its illegality, justifying the respondent's refusal to re-hire those responsible.
Main Doctrine
A strike staged in violation of the mandatory grievance procedure stipulated in a collective bargaining agreement, especially when accompanied by acts of coercion and intimidation, is illegal and unjustified.