Luzon Stevedoring Corp. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The cases involve disputes between Luzon Stevedoring Corporation and the Lusteveco Employees Association-CCLU. Following a decision and a resolution denying a motion for reconsideration, the Association sought leave to file a second motion for reconsideration. Procedural History: The Court of Industrial Relations had previously issued an order dated June 21, 1958, which granted strike duration pay. The Association made a return-to-work offer that invoked this order. The Association also raised issues concerning the reduction of the 1958 Christmas bonus, the dismissal of union members and bulk oil workers, and alleged misapprehension of facts regarding reduced working days. The existence of certain exhibits (A, A-1, A-2) was also contested. The Petition: The Lusteveco Employees Association filed a second motion for reconsideration, arguing that their return-to-work offer did not explicitly demand strike duration pay, despite invoking the June 21, 1958 order which granted it. They also reiterated arguments regarding the bonus reduction, dismissals, and the contested exhibits, pointing out a clerical error in the previous resolution.
Issue(s)
Whether the return-to-work offer implicitly included strike duration pay despite its non-mention, by invoking the Court of Industrial Relations order that granted it. Whether the issues concerning the reduction of the 1958 Christmas bonus, the dismissal of LEA members and bulk oil workers, and the alleged misapprehension of facts regarding reduced working days, as well as the existence of Exhibits A, A-1, and A-2, warrant reconsideration. Whether a clerical error in the previous resolution regarding the location of alleged documents affects the resolution of the issue.
Ruling
The Court denied the second motion for reconsideration for lack of merit. The Court found that the return-to-work offer, by invoking the June 21, 1958 order, implicitly incorporated the condition of strike duration pay. The Court also found no new reasons to change its stand on the other issues raised, which had already been discussed and resolved in the first motion for reconsideration. The identified clerical error was deemed inconsequential to the resolution of the controversy.
Ratio Decidendi
On the return-to-work offer and strike duration pay: The Court held that the Lusteveco Employees Association's return-to-work offer, by invoking the order dated June 21, 1958 of the Court of Industrial Relations, implicitly included the condition of strike duration pay. Although not explicitly mentioned in the offer itself, the invocation of the said order was precisely to incorporate by reference the terms and conditions set therein, including the granted strike duration pay. Therefore, the non-mention of strike duration pay in the offer did not negate its inclusion as a condition. On the reduction of bonus, dismissals, and misapprehension of facts: The Court found no new reasons to alter its previous stand on these issues. These matters, including the reduction of the 1958 Christmas bonus, the dismissal of 13 LEA members, the dismissal of 26 bulk oil workers, and the alleged misapprehension of facts concerning the reduction of working days of Anastacio Legaspi, were all raised and amply discussed in the first motion for reconsideration. The Court reiterated that the previous resolution adequately addressed these points. On the existence of Exhibits A, A-1, and A-2 and the clerical error: The Court acknowledged a clerical error in its previous resolution, where it stated "table of the union secretary" instead of "table of a company secretary." However, the Court clarified that this error did not affect the resolution of the issue. The controversy was not about whose table the alleged documents were found on, but rather whether the documents were lying around on the table or were inside a police log book placed on top of it. Therefore, the correction of the clerical error did not warrant a change in the Court's decision.
Main Doctrine
A second motion for reconsideration may be denied for lack of merit if it raises issues already discussed and resolved in the first motion for reconsideration, without presenting new reasons.