Philippine Fiber Processing Company v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an unfair labor practice charge filed by the Philfibco Employees and Laborers Union, Local 106 (NWB), against the Philippine Fiber Processing Company, Inc. The union alleged that the company illegally locked out its members on May 19, 1956. The company claimed it ceased operations due to a shortage of high-grade jute materials and incurred significant financial losses. The Court of Industrial Relations (CIR) found that the company's reasons were unsubstantiated, presenting evidence that the company had sufficient raw materials and continued operations elsewhere, thus concluding the lockout constituted an unfair labor practice. 2. Procedural History: The respondent union filed a complaint for unfair labor practice against the petitioner company on July 12, 1956. After extensive proceedings, the CIR rendered a decision on May 17, 1968, directing the company to reinstate the union members and pay back wages for three years. The petitioner received this decision on May 21, 1968. The petitioner sought an extension to file a motion for reconsideration, citing the voluminous record and change of counsel. This extension was denied by the CIR on May 25, 1968, due to its policy against extensions. The petitioner filed its motion for reconsideration on May 30, 1968. On October 28, 1968, the petitioner received the CIR's resolution dated September 24, 1968, dismissing its motion for reconsideration for being filed out of time. 3. The Petition: The petitioner filed an appeal by certiorari with the Supreme Court, challenging the CIR's dismissal of its motion for reconsideration. The core issue presented to the Supreme Court was whether the filing of a motion for an extension of time to file a motion for reconsideration tolled the five-day reglementary period for filing such a motion. The petitioner argued that the complexity and volume of the case, along with the late entry of its counsel, necessitated the extension. The Supreme Court, however, affirmed the CIR's decision, holding that a motion for extension does not toll the period for filing a motion for reconsideration, citing established jurisprudence. The Court also found the petitioner's reasons for seeking an extension to be without merit, given the length of time its counsel had been involved in the case.
Issue(s)
Whether the filing of a motion for extension of time to file a motion for reconsideration tolls the running of the reglementary period for filing said motion. Whether the petitioner company refused to bargain collectively with the complainant union. Whether the employees-members of the complainant union were illegally locked out, constituting an unfair labor practice act under Republic Act No. 875.
Ruling
The appeal is dismissed. The decision of the Court of Industrial Relations is affirmed. The CIR is enjoined to exert its utmost to locate and pay the benefits due to members of the respondent union who are entitled to the award, considering that some may be dead or have returned to their provinces.
Ratio Decidendi
On the issue of tolling the reglementary period: The Supreme Court held that the filing of a motion for extension of time to file a motion for reconsideration does not toll the running of the reglementary period. This procedural problem was resolved by citing the Court's decision in King vs. Joe, which affirmed the principle that the pendency of a motion for extension of time to perfect an appeal does not suspend the running of the period sought to be extended. The Court reiterated the stern warning from Garcia vs. Buenaventura that allowing such extensions would lead to a "glaring absurdity" where a mere filing of a petition for extension at the last hour would ipso facto extend the time. The "no-extension" policy of the CIR regarding motions for reconsideration was repeatedly upheld by the Supreme Court. Furthermore, the Court found the petitioner's reasons for seeking an extension to be baseless, as its counsel had been involved in the dispute since 1960 and had ample time to study the voluminous record. On the issue of refusal to bargain collectively: The industrial court absolved the petitioner from the charge of failure to bargain in good faith. This was based on two reasons: (a) the existence of two contending unions with claims of majority representation and dual union membership among employees, giving the petitioner reasonable grounds to doubt which union to deal with; and (b) despite a delay in response to a bargaining proposal, several conferences were held, which the CIR considered substantial compliance with Section 14 of the Industrial Peace Act. On the issue of illegal lockout and unfair labor practice: The CIR decided adversely against the petitioner. The Court found that the petitioner's notice to stop operations was based on alleged shortage of high-grade jute materials and financial losses. However, evidence showed that the company borrowed jute materials, expected a shipment, and had substantial stock in its bodega. The CIR's findings indicated that the company did not run short of jutes, as evidenced by the substantial stock and an incoming shipment. The fact that the company continued operations in Ma-ao, Negros Occidental, further belied the claim of insufficient materials and operating at a loss. The Court also found that the strike conducted by the Philippine Fiber Workers Union was initially peaceful, and incidents of violence, if any, occurred much later and were not reflective of the strike's conduct from the beginning. Therefore, the petitioner's lockout of the members of the respondent union on May 19, 1956, and thereafter, was in violation of the Industrial Peace Act.
Main Doctrine
A motion for extension of time to file a motion for reconsideration does not toll the running of the reglementary period for filing such motion. The "no-extension" policy of the Court of Industrial Relations regarding motions for reconsideration has been repeatedly upheld.