Talisay Employees & Laborers' Association v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Talisay Employees & Laborers' Association (TELA) and Free Visayan Workers (FVW) were rival unions at Talisay-Silay Milling Co., Inc. (TASIMICO). FVW won a certification election and was certified as the Collective Bargaining Unit. FVW demanded the lease of the Central to Talisay-Silay Industrial Cooperative Association (TASICA), which was organized a year earlier. Due to TASIMICO's failure to act on the demands, FVW struck on April 15, 1963. TELA members did not join the strike. TASIMICO entered into a contract of lease with TASICA on April 18, 1963, to terminate the strike, which was settled on April 29, 1963. Members of both unions were paid wages for April 1-14, but only FVW members received strike duration pay for April 15-29. On May 2, 1963, the Central was placed under military control. A petition for an administrator was filed and denied, but respondents were ordered to resume milling. Milling resumed on May 14, 1963, under military supervision, and concluded on June 5, 1963. Procedural History: On July 19, 1963, TELA filed a complaint for unfair labor practice against TASIMICO, TASICA, and Amado Araneta, alleging various acts of discrimination and aiding FVW. The trial court dismissed most charges for insufficiency of evidence but found respondents guilty of unfair labor practice for refusing to admit TELA members back to work due to their union affiliation, ordering reinstatement with backwages from April 15, 1963, to November 24, 1967. On motion for reconsideration, the Court of Industrial Relations (CIR) en banc affirmed the findings of fact but modified the decision, finding only TASICA guilty of unfair labor practice and liable for backwages for three years from April 29, 1963. TASIMICO, though absolved from backwages, was directed to re-admit complainants on a preferred basis. The Petition: Petitioners-appellants (TELA) filed a petition for certiorari and/or review of the CIR en banc resolution, arguing that all respondents should have been found guilty, the lease contract was invalid, TASIMICO should not have been absolved from backwages, backwages should cover the entire period of deprivation, TASIMICO should have been ordered to reinstate immediately, and the 15% salary increase deposit should be released.
Issue(s)
Whether the Court of Industrial Relations en banc erred in finding only TASICA guilty of unfair labor practice. Whether the Court of Industrial Relations en banc erred in holding the lease of the Central to TASICA valid and relieving TASIMICO from liability for backwages and immediate reinstatement. Whether the Court of Industrial Relations en banc erred in holding only TASICA jointly and severally liable for backwages. Whether the Court of Industrial Relations en banc erred in limiting the backwages to three years and not covering the entire period from the strike's commencement to actual reinstatement. Whether the Court of Industrial Relations en banc erred in merely allowing TASIMICO to reinstate complainants on a preferred basis instead of immediate reinstatement. Whether the Court of Industrial Relations en banc erred in not ordering the release of the 15% salary increase deposit to the petitioners.
Ruling
The Supreme Court affirmed the assailed resolution of the Court of Industrial Relations, ordering the National Labor Relations Commission (NLRC) to remit to petitioners the amount corresponding to their 15% salary increases deposited with the Court, to be paid in accordance with the rules and regulations of respondent Talisay Silay Milling Co., Inc. The Court found no cogent reason to disturb the findings of fact of the CIR, which were supported by substantial evidence. The Court also upheld the limitation of backwages to three years, citing jurisprudence and the interest of justice and expediency. TASIMICO was absolved from backwages due to the valid lease contract with TASICA, which assumed the liabilities arising therefrom. However, for humanitarian reasons, TASIMICO was ordered to reinstate TELA members on a preferred basis.
Ratio Decidendi
On the finding of unfair labor practice and liability: The Court reiterated the well-settled doctrine that the findings of fact of the Court of Industrial Relations, if supported by substantial evidence, are binding on the Supreme Court. The records showed that the Hearing Examiner conducted a thorough review of extensive evidence and testimonies. While the trial court found discriminatory acts after the strike, the CIR en banc modified this, holding only TASICA liable. The Court found no grave abuse of discretion in the CIR's findings, which were supported by a "seeming parade of positive credible evidence." The lease contract between TASIMICO and TASICA was deemed valid and effective, with TASICA assuming the obligations and responsibilities arising from the lease, including discriminatory acts committed against TELA members. On the validity of the lease and TASIMICO's liability: The Court found no error in the CIR en banc holding the lease of the Central to TASICA as valid for all legal intents and purposes. The evidence presented did not prove that the lease contract was simulated; rather, it was shown to be duly executed with legal formalities. Consequently, TASICA, as the lessee, assumed the control, operations, management, and the obligations and liabilities arising therefrom. Therefore, any discriminatory acts committed against the complainants, particularly the refusal of entry or admission back to work, were deemed the sole and exclusive responsibility of TASICA, absolving TASIMICO from direct liability for backwages. On the joint and several liability for backwages: The Court affirmed the CIR en banc's ruling that only TASICA was liable for backwages. This was based on the finding that the lease contract was valid and that TASICA, as the lessee, assumed the obligations and responsibilities arising from the operations of the sugar central during the lease period. The discriminatory acts, which led to the claim for backwages, were attributed to TASICA's management and control of the Central during the lease. Thus, TASIMICO, having leased out its operations, was not considered jointly and severally liable for the backwages incurred during the lease period. On the period of backwages: The Court did not err in limiting the backwages to a period of three years. Firstly, the contract of lease between TASIMICO and TASICA had a term of three years, during which TASICA was held solely responsible. Secondly, while the general rule in illegal dismissal cases is reinstatement with backwages from the time compensation was withheld up to reinstatement, the Supreme Court has, in numerous cases, adopted the policy of granting backwages for a maximum period of three (3) years without qualification and deduction, in the interest of justice and expediency. This policy was applied in the instant case. On immediate reinstatement vs. preferred basis: The Court found no error in the CIR en banc's directive for TASIMICO to reinstate complainants on a preferred basis. The Court cited jurisprudence, including American Jurisprudence, stating that an employer may not be compelled to reinstate a greater number of persons than the economic operation of its business requires. The Court noted that TASIMICO was absolved from backwages due to the valid lease contract. Ordering immediate reinstatement of all complainants would be impossible and would penalize TASIMICO for events over which it had no control. Reinstatement on a preferred basis, for humanitarian reasons and in line with the constitutional viewpoint of a compassionate society, was deemed appropriate. On the 15% salary increase deposit: The Court found the claim for the release of the 15% salary increase deposit to be tenable. The fact that the amount belonged to the workers and was deposited for safekeeping was not disputed. In the interest of harmony and peace, and to finally dispose of the case, the Court ordered the remittance of this amount to the petitioners, to be paid in accordance with the rules and regulations of TASIMICO.
Main Doctrine
The Court of Industrial Relations en banc erred in holding that only respondent TASICA was guilty of unfair labor practice and liable for backwages, and in limiting the backwages to three years, as the findings of fact supported by substantial evidence are binding on the Supreme Court, and the liability for discriminatory acts should be determined based on the evidence presented.