Luzon Glass Factory v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Employees of Luzon Glass Factory (Factory) organized the Far Eastern Luzon Glass Workers Union CLP (Union). The manager of the Factory and its sister company, Far Eastern Manufacturing Company, Inc. (FEMCO), Chu Tek Chen, expressed opposition and threatened dismissal if employees did not disaffiliate. Subsequently, five employees were either laid off or transferred to FEMCO. The Union charged the Factory, FEMCO, and Chu Tek Chen with unfair labor practices under the Industrial Peace Act. Procedural History: The trial judge dismissed the complaint for lack of substantial evidence. However, upon motion for reconsideration, the Court of Industrial Relations (CIR) en banc, in a majority resolution, reversed the trial court's decision, finding the Factory guilty of unfair labor practices. The CIR ordered the Factory to cease and desist and to reinstate the employees with backpay. The CIR also disregarded individual petitions to withdraw the case filed by three employees. The Petition: The Factory filed a petition for certiorari, challenging the CIR's resolution on the grounds that no employer-employee relationship existed between the Factory and the complaining workers, that the CIR erred in refusing to dismiss the case despite motions to withdraw, and that the award of backpay was excessive.
Issue(s)
Whether the CIR erred in finding an employer-employee relationship between the Factory and the complaining workers. Whether the CIR erred in refusing to dismiss the unfair labor practice case despite the motions to withdraw filed by three complaining workers. Whether the CIR erred in ordering the payment of backpay from the date of lay-off to the date of reinstatement, contrary to the ruling in Sta. Cecilia Sawmill, Inc. vs. CIR.
Ruling
The Supreme Court dismissed the appeal by certiorari. The parties, including the Factory and the Union, along with all five complaining employees, executed a joint motion to dismiss based on an amicable settlement of the controversy. The Court declared the case moot and academic.
Ratio Decidendi
On the employer-employee relationship and unfair labor practices: The Court did not directly rule on the merits of the employer-employee relationship or the unfair labor practices due to the subsequent amicable settlement. However, the CIR en banc had found that the Factory was guilty of unfair labor practices, holding that the employees were laid off due to union activities and that the transfer to FEMCO was a subterfuge to effect their dismissal. The CIR majority stressed the need for extra caution with pleadings of withdrawal, especially when the signatories testified in open court explaining their reasons. On the refusal to dismiss the ULP case: The CIR en banc majority refused to give credence to the individual petitions to withdraw, stating that such pleadings require extra caution and that the trial court should have considered the testimonies explaining the reasons for withdrawal over the allegations in the pleadings. The CIR considered one such pleading filed after the case was submitted for decision as a mere scrap of paper. On the award of backpay: The Factory argued that the backpay award was contrary to the ruling in Sta. Cecilia Sawmill, Inc. vs. CIR, which limited backpay to three months' salary. The respondent Union contended that the circumstances in the present case were materially different from Sta. Cecilia Sawmill, thus the doctrine was not applicable. The Supreme Court did not reach a definitive ruling on this issue due to the settlement.
Main Doctrine
The Supreme Court dismissed the appeal by certiorari as the parties arrived at an amicable settlement, rendering the case moot and academic.