Koppel (Philippines) Inc. v. El Tribunal de Relaciones Industriales
REITERATIONFacts
The Antecedents: Koppel (Philippines) Inc. and Koppel Employees Association entered into collective bargaining agreements in 1948 and 1949, which were renewed annually until October 18, 1952. A stipulation in the agreement provided for negotiation within sixty days before the expiration of the current agreement for the succeeding one. On September 3, 1952, the Association petitioned for a general wage increase. The management denied a general increase but granted it to ten deserving laborers. The Association insisted on a general increase, which was denied. On September 18, 1952, the Association threatened to enforce its rights if the demand was not met. Consequently, the laborers declared a strike on September 22, 1952. Procedural History: Koppel (Philippines) Inc. filed a petition with the Court of Industrial Relations (CIR) to declare the strike illegal. The CIR, through Commissioner Roldan, initially declared the strike illegal. However, upon motion for reconsideration, a majority of the CIR, consisting of Commissioners Jimenez Yanson, Lanting, and Judge Amparo, declared the strike legal, with Commissioners Roldan and Castillo dissenting. The Petition: Koppel (Philippines) Inc. filed a petition for certiorari with the Supreme Court, contending that the strike declared on September 22, 1952, was illegal.
Issue(s)
Whether the strike declared by the laborers was illegal. Whether the petitioner was deprived of its constitutional right to due process.
Ruling
The Supreme Court affirmed the resolution of the Court of Industrial Relations declaring the strike legal, with costs against the petitioner. The petition for certiorari was denied.
Ratio Decidendi
On the legality of the strike: The Supreme Court held that the strike declared by the laborers was legal. The Court distinguished the present case from previous rulings where strikes were declared illegal. In this case, the laborers did not infringe upon the existing agreement, which was valid until October 18, 1952. Instead, they exercised their right, as granted by the agreement, to negotiate for new terms within sixty days before the expiration of the current contract. When the management denied the general wage increase and only granted it to a few individuals, the laborers were justified in going on strike. The Court emphasized that a strike is an economic weapon, and its legality depends on its purpose and execution. It is legal when used to enforce a contract or assert rights granted therein, but illegal if used to violate a subsisting agreement or achieve an unlawful objective. The Court noted that the negotiations were for the succeeding collective bargaining agreement, not for any modification of the existing one, and the laborers were within their rights to use economic pressure when negotiations failed. On the alleged deprivation of due process: The Supreme Court found no merit in the petitioner's contention that it was deprived of due process. The Court explained that Judge Amparo, who was designated to sit in the CIR for the reconsideration of the motion, was not required to hear the parties again as it was a deliberation on a motion for reconsideration. Judge Amparo was only obligated to study the records, including the pleadings, evidence, the initial decision, and the arguments for and against the motion. His concurrence with the majority opinion, which was prepared by Commissioner Jimenez Yanson, did not constitute a pro forma concurrence. The Court clarified that the motion for reconsideration is a matter resolved in the court's deliberation chamber, not in an open session with parties' attendance.
Main Doctrine
A strike is considered legal when it is used to enforce compliance with a collective bargaining agreement or to assert rights granted therein, particularly when it arises from the employer's refusal to negotiate for new terms within the period stipulated in the existing agreement. Conversely, a strike is illegal if it is employed to violate a subsisting agreement, to trample upon the rights of the employer, or to destroy the enterprise.