Faculty Club v. Feati University
REITERATIONFacts
The Antecedents: The Feati University Faculty Club (PAFLU), composed of professors and instructors, declared a strike on February 18, 1963, due to the university's refusal to recognize their union and bargain collectively. The President of the Philippines certified the labor dispute to the Court of Industrial Relations (CIR) in the national interest. Procedural History: The CIR issued a return-to-work order on March 30, 1963, and an implementing order on April 6, 1963. The university challenged these orders, along with others, which were affirmed by the Supreme Court in a decision dated December 27, 1966. This decision upheld the CIR's jurisdiction, the employee status of the faculty members, the validity of the presidential certification, and the legality of the return-to-work order, emphasizing that the university had agreed to readmit strikers and that labor contracts must yield to the common good. The Supreme Court also affirmed the CIR's order for the arrest of university officers for indirect contempt and the withdrawal of a certification election petition. Subsequently, on February 7, 1969, the CIR issued an order for the execution of the return-to-work order, including the payment of accrued backwages from July 12, 1963, to the date of actual readmission, finding the university in bad faith for its failure to comply. This execution order was upheld by the Supreme Court in a resolution dated May 22, 1969. However, on November 24, 1969, the CIR issued a decision repudiating its earlier pronouncements, declaring the strike illegal and terminating the employee status of the participants. The Petition: The Feati University Faculty Club (PAFLU) filed the present petition seeking to reverse the CIR's November 24, 1969 decision, which nullified its earlier orders and Supreme Court affirmations regarding the return-to-work and backwages.
Issue(s)
Whether the CIR's November 24, 1969 decision, which declared the strike illegal and terminated employee status, is valid despite prior Supreme Court judgments affirming the return-to-work order and backwages. Whether the strike was illegal due to being an economic strike declared before the lapse of the 30-day cooling-off period. Whether the union members could be held liable for alleged acts of violence or coercion during picketing. Whether the faculty members are entitled to backwages from July 12, 1963, until their actual readmission.
Ruling
The Supreme Court reversed and set aside the CIR's decision of November 24, 1969. It ordered the CIR to implement without further delay the March 30, 1963 return-to-work order with accrued backwages, fixed at three years without deduction or qualification, and to resolve the merits of the labor dispute certified in 1963. The P50,000 injunction bond from the first Feati case was declared forfeited in favor of the petitioner. The P200 fine imposed on university officials for contempt was upheld.
Ratio Decidendi
On the validity of the CIR's November 24, 1969 decision: The Court held that the factual findings, conclusions, and orders rendered in the previous CIR proceedings, as affirmed by two final Supreme Court judgments, were res judicata and could no longer be reopened or set aside by the CIR. The CIR's subsequent decision, which repudiated its earlier orders and the Supreme Court's final pronouncements, was found to be bereft of factual and legal basis. The Court emphasized that issues resolved by final judgment, such as reinstatement with backwages, become the law of the case and may not be relitigated. On the legality of the strike: The Court found that the CIR's belated declaration of the strike's illegality was without basis. It reiterated that the return-to-work agreement on March 23, 1963, confirmed by the CIR's March 30, 1963 order, rendered the issue of the strike's legality moot. The Court noted that the strike was precipitated by unfair labor practices and union-busting tactics of the university, not merely an economic dispute requiring a cooling-off period. The university's actions, such as threatening mass dismissals and coercing faculty members to resign from the union, justified the strike as an unfair labor practice strike, even without a formal notice of strike or waiting out the cooling-off period. On liability for acts of violence: The Court ruled that the union officers and members could not be held liable for isolated instances of violence or coercion, as none of these incidents were shown to involve any member of the petitioner union. The union president's testimony that picketing was conducted without force and violence remained unchallenged. The Court invoked Section 9(c) of Republic Act No. 875, which states that no officer or member shall be held responsible for unlawful acts of individual officers, members, or agents except upon proof of actual participation, authorization, or ratification. The Court stressed that responsibility for sporadic acts must be individual, not collective, unless pervasive and widespread violence was deliberately promoted and countenanced by the union. On entitlement to backwages: The Court affirmed the faculty members' entitlement to backwages from July 12, 1963, until their actual readmission. It applied the precedent of fixing backwages to a just and reasonable level without qualification or deduction to avoid protracted delays. Considering the circumstances, including the preliminary injunction, the complexity of the issues, the nature of the institution, and the CIR's reversal, the Court fixed the backwages at the equivalent of three school years (ten months each) without deduction or qualification. The P50,000 injunction bond was also forfeited in favor of the petitioner.
Main Doctrine
A prior final judgment affirmed by the Supreme Court, which upheld a return-to-work order and awarded backwages, becomes res judicata and cannot be unilaterally repudiated by the industrial court. The industrial court's subsequent decision to declare the strike illegal and terminate employee status, despite prior rulings, is bereft of factual and legal basis.