Rizal Cement Workers Union v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: On September 2, 1954, the Union submitted proposals for a collective bargaining contract, which the respondent company refused, citing a pending case (Case No. 676-V) with the same demands, though the Union insisted the proposals were distinct. On October 5, 1954, the Union filed a Notice of Strike, and a conference on October 30, 1954, did not discuss the proposals. On November 4, 1954, another union, the Binangonan Labor Union (NWB), presented proposals and later entered into a collective bargaining contract with the respondent company. On May 27, 1956, the Union declared a strike against the respondent company at its plant in Binangonan, Rizal, and the dispute was certified by the President to the Court of Industrial Relations (CIR). Procedural History: The CIR found that the strike commenced on May 27, 1956, with picketing, and a Philippine Constabulary detachment was assigned to maintain peace. During the strike, a PC officer was injured, some workers were unable to work, stones were hurled at the company's motor launch, breaking its windshield, and the company's timekeeper, Jose Beltran, was found dead near the strike area. A collective bargaining agreement was entered into between the respondent and intervenor on November 10, 1954, and an injunction order in Case No. 676-V, issued on March 18, 1952, prohibited lockouts by the respondent and strikes by the employees. On February 28, 1957, the Union offered to allow its striking members to return to work. The CIR concluded that the strike was justified, despite isolated acts of violence, and ordered the company to reinstate striking members without back wages. Both the Union (for back wages) and the Company (for justifying the strike) moved for reconsideration, which the CIR denied. The Petition: The Union appealed to the Supreme Court, arguing that since the CIR found the strike justified, it erred in not awarding back wages. They contended that depriving employees of wages due to a lockout violates Section 15 of Republic Act No. 875 and Philippine jurisprudence.
Issue(s)
Whether the refusal of the company to accept the strikers' offer to return to work during the pendency of the labor dispute constituted a 'lockout' entitling the employees to backpay under Section 15 of Republic Act (RA) No. 875. Whether the Court of Industrial Relations (CIR) committed a grave abuse of discretion in denying back wages to members of a union whose strike was declared justified but was attended by isolated acts of violence.
Ruling
The petition is dismissed, and the decision of the Court of Industrial Relations is affirmed.
Ratio Decidendi
On Issue 1: The Court held that there was no lockout in the legal sense. Under Section 15 of Republic Act (RA) No. 875, a lockout is an act committed by the employer who refuses to give work to its workers. In this case, the cessation of work was the result of a strike declared and maintained by the Union through picketing. The Union's theory of a 'virtual lockout'—arising from the company's refusal to accept an offer to return to work during the pendency of the case—is not recognized by law. A strike, which is a voluntary cessation of work by employees, cannot be converted into a lockout by the mere filing of a notice of offer to return to work while the dispute is being litigated. Since the work stoppage was initiated by the strikers, the provision on backpay for locked-out employees does not apply. On Issue 2: The Court of Industrial Relations (CIR) acted within its broad discretionary powers when it denied back wages. When a labor dispute is certified by the President under Section 10 of Republic Act (RA) No. 875, the CIR's powers are governed by Commonwealth Act (CA) No. 103, which grants it authority for compulsory arbitration. Applying the doctrine in Phil. Marine Radio Officers Association vs. CIR, the Court reaffirmed that the power to fix terms and conditions of employment includes the power to order reinstatement with or without backpay. The CIR found that the strike was attended by isolated acts of violence and emotional outbursts. Consequently, the CIR's decision to reinstate the workers without back wages was a fair adjustment, placing the parties in a situation where 'one gained none for the fault of the other.' There was no showing of grave abuse of discretion in this equitable determination.
Main Doctrine
The Court of Industrial Relations, when a labor dispute is certified by the President, possesses broad powers of arbitration under Commonwealth Act No. 103, including the authority to order reinstatement with or without back wages, as a term or condition of employment, even if the strike was attended by isolated acts of violence, provided a degree of reason and fairness is afforded to the strikers.