Pampanga Sugar Development Co. v. Sugar Workers' Association
REITERATIONFacts
1. The Antecedents: During the 1955-1956 milling season, members of the respondent Sugar Workers Association (SWA) declared a strike against the petitioner, Pampanga Sugar Development Co., Inc. (Pasudeco). The dispute was certified to the Court of Industrial Relations (CIR) by the President. This Court previously upheld the CIR's jurisdiction and the validity of the certification in G.R. No. L-13178. 2. Procedural History: On November 7, 1961, the CIR ordered the strikers to return to work, a directive affirmed en banc on September 25, 1962, which also mandated maintaining the status quo as of the strike's declaration. Subsequent hearings led to orders for the readmission of 130 out of 239 strikers. The CIR addressed the remaining strikers, declaring 8 to have abandoned work due to other employment, deferring resolution for 12 due to old age, and deferring readmission for 62 convicted by a municipal court pending appeal. Pasudeco claimed 20 additional strikers had gained employment elsewhere, naming 9 specifically. An order on January 29, 1965, directed the reinstatement of these 9 strikers unless they were employed elsewhere or uninterested. After a motion for reconsideration, the CIR en banc on September 1, 1966, ordered the 9 strikers to show cause within 15 days why their failure to report for work should not be considered abandonment. The SWA failed to comply, and on December 15, 1966, an order declared the 9 strikers to have abandoned their employment. A subsequent petition to reopen was denied on March 11, 1968. However, on July 9, 1969, the CIR en banc, by a 3-1 vote, reconsidered previous orders and directed the immediate return to work of the 9 strikers. 3. The Petition: Pasudeco filed this petition for certiorari seeking to set aside the CIR's July 9, 1969 resolution, arguing it altered a final and unappealable resolution of September 1, 1966. Pasudeco contends the CIR erred in altering the September 1, 1966 resolution, which ordered the strikers to show cause for their failure to report, and in reconsidering the December 15, 1966 order declaring abandonment and the March 11, 1968 order denying the petition to reopen. Pasudeco asserts the 9 strikers never signified their intent to return to work, had secured other employment, and that the union's petition to reopen was filed improperly. The petition argues that the CIR resolution of July 9, 1969, was issued in grave abuse of discretion and should be nullified, reviving the December 15, 1966 and March 11, 1968 orders.
Issue(s)
Whether the CIR en banc committed grave abuse of discretion in issuing its resolution of July 9, 1969, which altered prior final and unappealable orders. Whether the nine strikers, who failed to show cause for their absence and were found to be gainfully employed elsewhere, should be considered to have abandoned their employment and thus be disentitled to reinstatement and back wages.
Ruling
The petition for certiorari is granted. The resolution en banc of the CIR dated July 9, 1969, is nullified and set aside. The orders dated December 15, 1966, and March 11, 1968, are revived and upheld.
Ratio Decidendi
On the issue of grave abuse of discretion and alteration of final orders: The Court held that the CIR committed grave abuse of discretion in issuing its resolution of July 9, 1969. This resolution altered the CIR's own resolution of September 1, 1966, which had become final and executory. The resolution of September 1, 1966, ordered the nine strikers to show cause within fifteen (15) days why their failure to report for work should not be considered abandonment. The SWA failed to comply with this order, and the nine strikers never appeared to signify their desire to return to work. The Court emphasized that judicial and administrative determinations must have stability and that allowing them to be reopened or set aside at any time would render them a mockery. The principle that a judgment becomes final and unappealable after the expiration of the period for appeal, and the court loses control over it except for execution, was invoked. The CIR's resolution of July 9, 1969, which revived an earlier order that had been superseded, was deemed an unlawful alteration of a final judgment. On the issue of abandonment of employment: The Court affirmed the CIR's order of December 15, 1966, which declared the nine strikers to have abandoned their employment. This conclusion was based on their failure to report for work, their failure to show cause as required by the September 1, 1966 resolution, and the uncontradicted claim that they had secured gainful employment elsewhere. The Court reasoned that the strikers never presented themselves to the company to claim readmission, nor did they signify their willingness to return to work. The petition to reopen was filed by the union, not the strikers themselves, and did not allege their interest in returning. The prolonged period of absence, coupled with securing other employment, strongly indicated an intent to renounce their former positions. The Court noted that the union's motivation might have been to benefit from back wages rather than the strikers' actual return to work, given their new lucrative employment.
Main Doctrine
The Court of Industrial Relations (CIR) committed grave abuse of discretion in issuing a resolution that altered a prior final and executory order declaring certain strikers to have abandoned their employment, particularly when the strikers failed to show cause for their absence and had secured gainful employment elsewhere.