Free Telephone Workers Union v. Philippine Long Distance Telephone Company
REITERATIONFacts
The Antecedents: Petitioner Free Telephone Workers Union (FTWU) declared a strike on November 1, 1964, due to an impasse in negotiations for a 20-point economic demand, including a wage increase for three years. The President certified this labor dispute to the Court of Industrial Relations (CIR) on November 3, 1964, as it affected an industry indispensable to national interest. On November 9, 1964, the CIR issued a partial decision, ordering a P0.16 per hour wage increase for rank-and-file employees for one year and directing the union members to return to work, prohibiting strikes during the pendency of the case. Procedural History: FTWU appealed the wage increase amount, which the Supreme Court affirmed on July 31, 1970. On March 3, 1965, FTWU and Philippine Long Distance Telephone Company (PLDT) agreed to refer future disputes to the union president and company controller for settlement, or to the courts as incidents of CIR Case No. 51-IPA if not settled amicably. Following the enactment of Republic Act No. 4180 (raising the minimum wage to P6.00/day), PLDT adjusted wages for employees below the new minimum. FTWU sought wage re-adjustment negotiations for those already earning P6.00, which PLDT refused, considering it connected to the pending wage dispute. FTWU then demanded a P0.25 per hour wage increase and filed a notice of strike on May 17, 1965, alleging unfair labor practice for PLDT's refusal to negotiate. PLDT petitioned the CIR for a preliminary injunction on June 2, 1965, to prevent the strike, citing the March 3, 1965 agreement and the November 9, 1964 order. FTWU moved to dismiss, questioning the CIR's jurisdiction. On July 6, 1965, the CIR issued a temporary restraining order. On July 7, 1965, FTWU declared a strike, citing the dismissal of two members and PLDT's refusal to negotiate wage adjustments. PLDT moved to declare the strike illegal and sought contempt charges against union officers. On July 16, 1965, the CIR denied FTWU's motion to dismiss, ordered the union to call off the strike and lift picket lines, directed striking employees to return to work within three days, and authorized PLDT to replace those who failed to return, with the possibility of reinstatement after due hearing. FTWU moved for reconsideration, which was denied by the CIR en banc on July 31, 1965. FTWU then filed the present petition with the Supreme Court. The Petition: FTWU seeks a review of the CIR's July 6 and 16, 1965 orders and the July 31, 1965 en banc resolution, primarily questioning the CIR's jurisdiction over the dispute that led to the second strike and the issuance of the injunction and replacement orders.
Issue(s)
Whether the CIR had jurisdiction over the second labor dispute concerning wage adjustments prompted by Republic Act No. 4180, which arose after the initial certification of the labor dispute. Whether the CIR's order directing the lifting of peaceful picket lines violated the constitutional guarantee of freedom of speech. Whether the CIR validly authorized the company to replace striking employees who failed to return to work within the specified period without a prior hearing on termination. Whether the CIR erred in granting injunctive relief without the company exhausting negotiation remedies and in issuing the orders without regard to procedural due process.
Ruling
The Supreme Court affirmed the July 6 and 16, 1965 orders and the July 31, 1965 en banc resolution of the respondent Court of Industrial Relations. The Court held that the CIR had jurisdiction over the incident, the order to lift picket lines was limited to illegal picketing, and the authorization for replacement of striking employees was a valid provisional sanction.
Ratio Decidendi
On the CIR's jurisdiction over the second wage dispute: The Court ruled that the CIR had jurisdiction. The second demand for wage increase, arising from Republic Act No. 4180, was an incident of the main labor dispute certified by the President on November 3, 1964. The original dispute involved a three-year period for wage increases, and the partial decision of November 9, 1964, only settled the first year. Therefore, any demand for wage adjustment within that three-year period, even if prompted by new legislation, was still connected to the certified dispute. The CIR's jurisdiction, once invoked by Presidential certification, extends to all incidents of the main case, reviving its compulsory arbitration powers under Commonwealth Act No. 103. The Court cited precedents like Cebu Portland Cement Co. v. Cement Workers Union and Talisay-Silay Milling Co., Inc. vs. CIR to support the principle that jurisdiction over the principal action includes its incidents. On the issue of peaceful picketing and freedom of speech: The Court clarified that the CIR's order to lift picket lines did not prohibit peaceful picketing, which is protected by freedom of speech. The order was directed at the strike declared on July 7, 1965, and enjoined persons manning picket lines from impeding the implementation of the court's order and interfering with the company's operations. This was interpreted as referring to illegal picketing, not peaceful assembly, consistent with the ruling in Mortera v. CIR. The Court emphasized that the order was aimed at preventing interference with operations and ensuring compliance with the return-to-work directive, not at suppressing legitimate expression. On the authorization to replace striking employees: The Court upheld the CIR's authority to allow the company to replace striking employees who failed to return to work within three days, as provided by Section 19 of Commonwealth Act No. 103. This was considered a provisional sanction to enforce obedience to the court's return-to-work order, especially given the national interest involved in the company's business. The Court distinguished this from termination due to an illegal strike, which requires a hearing. The authorization was provisional, and the replaced employees retained the right to seek reinstatement after due hearing and establishing good and valid grounds for their failure to return. The Court noted that in a related case, replaced employees were indeed ordered reinstated, subject to conditions. On exhaustion of remedies and due process: The Court found no merit in the contention that the company failed to exhaust negotiation remedies. Since the dispute was an incident of a certified labor case already under compulsory arbitration, further negotiation was not a prerequisite for the CIR's intervention. Regarding due process, the Court stated that the CIR's orders were issued within its established jurisdiction over the main case and its incidents. The petitioner had the opportunity to be heard through its motions to dismiss and for reconsideration, curing any alleged procedural deficiencies. The orders were based on sufficient facts on record and disclosed to both parties, satisfying the requirements of due process as established in Ang Tibay v. CIR.
Main Doctrine
The Court of Industrial Relations (CIR) has jurisdiction over disputes and incidents arising from a labor dispute certified by the President, even if such disputes involve new legislation enacted after the certification, as long as they are connected to the original certified dispute. A return-to-work order, when public interest demands and the dispute cannot be promptly settled, is a valid provisional sanction that does not require a prior hearing on termination, though replaced employees may be reinstated after due hearing.