National Fastener Corp. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The underlying dispute concerns the dismissal of Celestino Blas, an employee of the National Fastener Corporation of the Philippines and Sergeant-at-arms of the National Fastener Employees Association (PTUC). The corporation was accused of unfair labor practice under Republic Act No. 875, specifically for dismissing Blas to discourage union membership and because he testified in a previous unfair labor practice case against the company. Procedural History: The National Fastener Corporation was charged with unfair labor practice in a complaint dated November 29, 1958. After a hearing, the Presiding Judge of the Court of Industrial Relations, Jose S. Bautista, rendered a decision on June 13, 1959, finding the corporation guilty of unfair labor practice and ordering the reinstatement of Celestino Blas without backpay. Both parties filed motions for reconsideration, leading to an en banc resolution on July 17, 1959, which affirmed the finding of unfair labor practice but modified the decision to include back wages for Blas. Judge Bautista dissented from this modification. The Petition: The National Fastener Corporation filed a petition for certiorari with the Supreme Court, seeking to set aside the en banc resolution of the Court of Industrial Relations. The petitioner contends that the Court of Industrial Relations abused its discretion in ordering the reinstatement of Celestino Blas with backpay, in finding the petitioner guilty of unfair labor practice, and in not upholding the petitioner's position that Blas' dismissal was justified due to absenteeism.
Issue(s)
Whether the Court of Industrial Relations gravely abused its discretion in finding the petitioner corporation guilty of unfair labor practice. Whether the Court of Industrial Relations gravely abused its discretion in ordering the reinstatement of Celestino Blas with back wages.
Ruling
The resolution of the Court of Industrial Relations en banc ordering the reinstatement of Celestino Blas with back wages and finding the petitioner corporation guilty of unfair labor practice is affirmed. Costs are against the petitioner-appellant.
Ratio Decidendi
On Issue 1: The Supreme Court found no merit in the contention that the Court of Industrial Relations (CIR) abused its discretion in finding the petitioner guilty of unfair labor practice. The Court acknowledged that Celestino Blas had committed certain irregularities, including alleged absences, but noted that most of these occurred long before his dismissal and for which he had already been reprimanded. While the petitioner cited Blas's absences from July 7 to July 19, 1958, as the immediate cause, Blas counter-testified that he had secured permission for vacation leave without pay from the company president. The Supreme Court deferred to the factual findings of the Industrial Court, which had the opportunity to examine and appraise the factual issues and assess credibility. Furthermore, substantial evidence supported the finding of unfair labor practice, including testimony that Blas was approached and instructed to not affiliate with the union, was promised a raise to discourage membership, and received a stern warning after joining the union and testifying in another unfair labor practice case. The Court also pointed out that other employees who incurred absences without leave were not dismissed, indicating discriminatory treatment against Blas. A report to management, which preceded Blas's dismissal, specifically mentioned his union membership and a pending case, suggesting an anti-union motive. The Court dismissed the petitioner's argument that dismissing a less active union official like Blas was illogical, stating that it would have made the discriminatory design too obvious otherwise. The decision of the Industrial Court was found to be sustained by substantial evidence, noting that the presence of conflicting circumstances does not warrant reversal, as the issue is the credibility of the evidence relied upon, not the preponderance of evidence. On Issue 2: The Supreme Court held that the Court of Industrial Relations did not abuse its discretion in awarding back wages to Celestino Blas. The Court emphasized that the matter of awarding backpay rests within the sound discretion of the Industrial Court, as explicitly provided by Section 5(a) of Republic Act No. 875. This discretionary power of the CIR in determining appropriate remedies, including monetary compensation for lost earnings due to unfair labor practice, has been consistently upheld in Philippine jurisprudence. The Court cited its previous ruling in Velez vs. PAV Watchman's Union and the Court of Industrial Relations, G.R. No. L-12639, April 27, 1960, to reinforce the principle that the CIR possesses the authority to include back wages in its orders to ensure full redress for employees subjected to unfair labor practices. Therefore, the modification by the CIR en banc to include back wages in Blas's reinstatement order was deemed a valid exercise of its discretion and not a grave abuse thereof.
Main Doctrine
The Court of Industrial Relations did not abuse its discretion in ordering the reinstatement of an employee with back wages and finding the corporation guilty of unfair labor practice, where the dismissal, despite alleged grounds of absenteeism, was found to be motivated by the employee's union affiliation and testimony in a previous unfair labor practice case, and where the findings of the Industrial Court were supported by substantial evidence.