Philippine Educational Institution v. MLQSEA Faculty Association
REITERATIONFacts
The Antecedents: Dionisio Q. Quimosing, a professor at Philippine Educational Institution (PEI), was elected president of the MLQSEA Faculty Association. PEI was informed of his election. Subsequently, unfair labor practice charges were filed against PEI and Leoncio B. Monzon on behalf of the union and its dismissed members. Quimosing's teaching load was reduced, and he was informed he would not be given an assignment for the next semester. Procedural History: The Court of Industrial Relations (CIR) found PEI guilty of unfair labor practice and ordered the reinstatement of Quimosing with backpay. A motion for reconsideration was denied. The CIR's decision was sought to be reviewed by PEI and Monzon. The Petition: Petitioners contended that the CIR erred in finding them guilty of unfair labor practice and in ordering reinstatement with backpay. A crucial point raised was the alleged dissolution of PEI as of March 12, 1964, evidenced by a Certificate from the Securities and Exchange Commission, rendering reinstatement impossible.
Issue(s)
Whether the Court of Industrial Relations has the power to inquire into alleged unfair labor practice acts. Whether the findings of fact by the Court of Industrial Relations are conclusive. Whether the dissolution of the petitioner corporation affects the right to reinstatement and backpay.
Ruling
The decision of the Court of Industrial Relations finding the petitioners guilty of unfair labor practice acts is affirmed. However, the case is remanded to the Court of Industrial Relations for a determination of whether the Philippine Educational Institution was dissolved as of March 12, 1964, and if so, to fix the extent and scope of the right to back wages up to the date of dissolution. If dissolution is not established, the CIR should proceed accordingly.
Ratio Decidendi
On the power of the Court of Industrial Relations to inquire into unfair labor practice acts: The Court affirmed that the power of the Court of Industrial Relations to inquire into alleged unfair labor practice acts is well-settled. It reiterated that faculty members of educational institutions are entitled to the full protection of the Industrial Peace Act. The Court emphasized that the facts found by the CIR should remain undisturbed in the absence of a showing of grave abuse of discretion, which would normally validate the CIR's decision regarding unfair labor practice and the right to reinstatement with backpay. On the conclusiveness of findings of fact by the Court of Industrial Relations: The Court extensively discussed and reiterated the doctrine that findings of fact made by the Court of Industrial Relations are conclusive and will not be disturbed by the Supreme Court, absent a clear showing of grave abuse of discretion. This doctrine, traced from early decisions, holds that the Supreme Court is not authorized to make a factual inquiry, as the ruling of the CIR is considered decisive. The Court stressed that as long as there is evidence to support the decision, it should not be reversed merely because it is not based on overwhelming or preponderant evidence, but rather on substantial or credible evidence. On the effect of corporate dissolution on reinstatement and backpay: The Court acknowledged the allegation, supported by a Securities and Exchange Commission certificate, that the Philippine Educational Institution was dissolved as of March 12, 1964. It recognized that if true, reinstatement to a former position would be impossible as the school is closed and the corporation is in liquidation. The Court noted that the respondents argued that this issue could be determined during the implementation phase of the decision. However, considering the principle of adherence to due process and the need for administrative agencies to decide relevant issues, the Court deemed it more desirable to remand the case to the CIR for an express finding of fact on the dissolution and its implications on Quimosing's right to reinstatement and backpay.
Main Doctrine
The Court of Industrial Relations has the power to inquire into alleged unfair labor practice acts. Findings of fact by the Court of Industrial Relations are conclusive and will not be disturbed in the absence of a showing of grave abuse of discretion. However, the enforceability of reinstatement and backpay rights must be inquired into if the employer corporation has been dissolved.