Balaquezon Employees & Workers Transportation Union v. Presidential Assistant for Legal Affairs
REITERATIONFacts
The Antecedents: The Balaquezon Employees & Workers Transportation Union declared a strike in June 1957 against the Batangas Laguna Tayabas Bus Co. After conciliation efforts and a certification election, the union declared another strike on September 8, 1957, leading to the dispute being certified to the Court of Industrial Relations (CIR). Procedural History: The CIR declared the strike illegal in 1959, ordering the dismissal of union officers and reinstatement without backwages for union members. This Court denied review. Subsequent petitions by the union for reopening the case, modification of the decision, and contempt for non-compliance with reinstatement orders were also dismissed by the CIR and this Court over several years. After the CIR's abolition, the National Labor Relations Commission (NLRC) implemented the 1959 decision. A Labor Arbiter identified 150 employees for reinstatement and awarded backwages of 18 months for some and 6 months for others. The NLRC modified this to 6 months for all 150 employees. The Secretary of Labor increased the award to 12 months. The Presidential Assistant for Legal Affairs (PALA) modified this again, reaffirming the NLRC's 6-month backwages award as an alternative to reinstatement, and sustained the exclusion of 73 employees. The Petition: The union filed a special civil action for certiorari with the Supreme Court, assailing the PALA's decision. The union contended that the backwages should be equivalent to three years' compensation, arguing for an adjustment in light of existing jurisprudence and the circumstances of the case. The union also questioned the exclusion of seventy-three employees from receiving benefits.
Issue(s)
Whether the award of six months' backwages to striking employees, in lieu of reinstatement, is equitable and justified. Whether seventy-three employees were unjustly excluded from receiving monetary benefits.
Ruling
The petition is dismissed. The decision of the Presidential Assistant on Legal Affairs, by authority of the President of the Philippines, is affirmed. No costs.
Ratio Decidendi
On Issue 1: The Court found no grave abuse of discretion committed by the Labor Arbiter, the NLRC, the Secretary of Labor, and the Presidential Legal Assistant in awarding six months' backwages to the one hundred fifty striking employees as an alternative to reinstatement. The Court underscored that these backwages are awarded on equitable considerations or in the nature of severance pay, recognizing that reinstatement may no longer be feasible due to the long passage of time or the "realities of the situation." While the Labor Arbiter initially fixed the award at eighteen months for some and six months for others, and the Secretary of Labor increased it to twelve months, the PALA ultimately reaffirmed the NLRC's resolution of six months. The Court found this six-month award to be "most in keeping with the demands of equity" and was disinclined to disturb it, considering the twenty-two-year duration of the litigation since 1957. On Issue 2: The Court found no injustice in the exclusion of seventy-three employees from reinstatement or monetary benefits. The union failed to elaborate on its stand regarding these employees in its memorandum and did not refute the findings of the Labor Arbiter, who noted that their names were not found in relevant pleadings, or they had abandoned their jobs, or for other reasons. The union was given an opportunity to present evidence but failed to persuade the Labor Arbiter. The Court deemed it improper at that late stage to remand the case for another hearing, emphasizing the need to avoid further prolonging the protracted litigation.
Main Doctrine
The Supreme Court affirmed the decision of the Presidential Assistant for Legal Affairs, which limited the award of backwages to six months' salary for striking employees as an alternative to reinstatement. The Court found no grave abuse of discretion on the part of the administrative officials in fixing this amount, considering the equitable nature of the award and the long passage of time since the original labor dispute arose in 1957. The Court also upheld the exclusion of seventy-three employees from receiving benefits due to insufficient evidence presented by the union to justify their reinstatement or inclusion in the award.