National Labor Union v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The National Labor Union (NLU) filed a complaint for unfair labor practice against Victory Liner, Inc. (VLI). NLU alleged that Pacifico Navarro, a driver employed by VLI since June 10, 1959, was refused trip assignments from March 23, 1959, to September 1959, solely due to his union membership and activities. It was further alleged that on September 5 or 6, 1959, VLI's general manager confronted Navarro about his meetings with union officers, became angry, and told Navarro to seek work from his union. On September 8, 1959, Navarro was dismissed without just or valid cause, but for his continued union membership and activities. Procedural History: The trial judge of the Court of Industrial Relations (CIR) found VLI guilty of unfair labor practice and ordered the reinstatement of Pacifico Navarro with back wages. VLI moved for reconsideration. The CIR en banc reversed the trial judge's decision, absolved VLI from the charge of unfair labor practice, and set aside the order of reinstatement. The Petition: NLU appealed the resolution of the CIR en banc to the Supreme Court, arguing that the CIR erred in not finding VLI guilty of unfair labor practice and in not ordering Navarro's reinstatement.
Issue(s)
Whether the respondent Court of Industrial Relations erred in not finding the private respondent guilty of unfair labor practice. Whether the respondent Court of Industrial Relations erred in not reinstating Pacifico Navarro with back wages.
Ruling
The resolution of the Court of Industrial Relations en banc absolving Victory Liner, Inc. from the charge of unfair labor practice is affirmed. The appeal is devoid of merit.
Ratio Decidendi
On the issue of unfair labor practice: The Supreme Court held that the findings of fact of the Court of Industrial Relations sitting en banc are conclusive and will not be reviewed by the Supreme Court unless they are not supported by substantial evidence. The petitioner failed to point out specific portions of the resolution that lacked substantial evidence. The CIR en banc's resolution was predicated on the evidence presented by the parties and the trial judge's decision. The CIR is governed by the rule of substantial evidence, not preponderance of evidence. Therefore, the Court found no error in the CIR en banc's exoneration of VLI from the charge of unfair labor practice. On the issue of reinstatement with back wages: The Supreme Court reiterated that the resolution of the case hinges on the correctness of the CIR en banc's decision absolving VLI from unfair labor practice. The petitioner's insistence on reinstatement, based on the trial judge's finding of dismissal without just cause, was considered a change of theory. Even if the dismissal was without just cause, the CIR en banc would not have the authority to order reinstatement if the unfair labor practice charge failed. However, the Court noted that the dismissed employee is not without remedy, as a breach of obligation by the employer may be redressed like an ordinary contract or obligation, citing National Labor Union vs. Insular Yebana Tobacco Corporation.
Main Doctrine
The findings of fact of the Court of Industrial Relations sitting en banc are conclusive in the absence of a showing that they have no support in evidence, as the said court is governed by the rule of substantial evidence. Furthermore, a claim for reinstatement with back wages, predicated on a finding of unfair labor practice, cannot be sustained if the charge of unfair labor practice itself fails.