Liner v. National Labor Union
REITERATIONFacts
The Antecedents: Respondent Emiliano Silva, a bus driver for petitioner G. Liner since 1957, joined the National Labor Union (NLU) in February 1959. On March 5, 1959, Silva reported for work and was assigned an old bus, which he felt was discriminatory. After making three trips, he returned the bus to the garage and left a note stating he would complain to the Department of Labor about an undue change in his employment conditions. Upon returning later that day, he was prevented from signing the dispatcher's book for the next day's work. He was told to see petitioner Jose De Keyser, the company manager, who expressed displeasure at Silva's complaint. Subsequently, the company investigator sent letters to Silva and three other drivers asking them to return to work, but only two were reinstated. Silva's attempts and those of the NLU to secure his return proved futile. Procedural History: The acting prosecutor of the Court of Industrial Relations (CIR) filed a complaint for unfair labor practice against petitioners. The CIR en banc declared petitioners guilty of unfair labor practice and ordered them to reinstate respondent Emiliano Silva to his position as driver with back wages, computed from March 5, 1959, to the date of reinstatement, excluding a specific period. The Petition: Petitioners sought review of the CIR decision, questioning the findings of fact and the resolution for the payment of full back wages.
Issue(s)
Whether the findings of fact of the Court of Industrial Relations are supported by substantial evidence and thus conclusive upon the Supreme Court. Whether the Court of Industrial Relations correctly ordered the payment of full back wages to the dismissed employee.
Ruling
The Supreme Court affirmed the judgment under review. The findings of fact of the CIR were upheld due to substantial evidence. The order for payment of full back wages was also affirmed, applying the guidelines set in Itogon-Suyoc Mines, Inc. vs. Sañgilo-Itogon Workers' Union for the computation of back wages.
Ratio Decidendi
On the issue of findings of fact: The Court reiterated its consistent adherence to the principle that the findings of fact of the CIR will not be disturbed provided substantial evidence exists in support thereof. The petitioners' attempt to question the veracity of respondent Silva's testimony and dissect the evidence to claim a greater weight in their favor was unavailing. Since substantial evidence was found to be before the Court, the CIR's findings of fact were deemed conclusive. This principle ensures stability and finality in labor dispute resolutions, preventing endless re-litigation of factual matters. On the issue of back wages: The Court distinguished the present case from Fernando vs. Angat Labor Union and Sta. Cecilia Sawmills, Inc. vs. Court of Industrial Relations, where liability for back wages was limited due to sale of the business or closure due to business losses. Instead, the Court found the ruling in Itogon-Suyoc Mines, Inc. vs. Sañgilo-Itogon Workers' Union to be controlling. In Itogon-Suyoc Mines, where dismissal was due to unfair labor practice, the employees were held entitled to back wages from the date of dismissal to actual reinstatement. The Court applied the guidelines established in Itogon-Suyoc Mines for the computation of back wages, which include deducting earnings from other employment and considering whether the employee could have obtained suitable remunerative employment through due diligence.
Main Doctrine
The findings of fact of the Court of Industrial Relations (CIR) will not be disturbed provided substantial evidence exists in support thereof. In cases of unfair labor practice, employees are entitled to back wages from the date of dismissal to the date of actual reinstatement, with deductions for earnings from other employment and consideration for potential income from suitable employment.