Kiok Loy v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: The Pambansang Kilusang Paggawa (Union) won a certification election and was certified as the sole bargaining agent for the rank-and-file employees of Sweden Ice Cream Plant (Company). The Union furnished the Company with its proposed collective bargaining agreement (CBA) and requested counter-proposals, but the Company failed to respond. Procedural History: The Union filed a notice of strike due to unresolved economic issues. Conciliation proceedings failed, and the case was certified to the National Labor Relations Commission (NLRC) for compulsory arbitration. The Labor Arbiter granted postponements to the Company, but ultimately denied a further postponement and considered the case submitted for resolution after the Company's representative failed to appear for examination and the Company waived its right to present further evidence. The NLRC found the Company guilty of unfair labor practice for unjustified refusal to bargain and declared the Union's draft proposal as the governing CBA. The Petition: The Company filed a petition for certiorari with the Supreme Court, assailing the NLRC decision, alleging violation of procedural due process due to the denial of its motion for postponement and claiming that the finding of unfair labor practice was unsupported by evidence, as they only received the proposed CBA on May 24, 1979. They also argued the adopted CBA was unreasonable and lacked legal basis.
Issue(s)
Whether the National Labor Relations Commission acted without or in excess of its jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction in rendering the challenged decision. Whether the Company was denied its right to procedural due process when the Labor Arbiter denied its motion for further postponement and precluded it from presenting further evidence. Whether the National Labor Relations Commission's finding of unfair labor practice for refusal to bargain is supported by law and evidence. Whether the Collective Bargaining Agreement approved and adopted by the National Labor Relations Commission is unreasonable and lacks legal basis.
Ruling
The petition lacks merit and is hereby dismissed. The temporary restraining order issued is lifted and set aside.
Ratio Decidendi
On the overall jurisdiction and grave abuse of discretion: The Court found that the NLRC acted within its jurisdiction. Collective bargaining is a mutual responsibility and a legal obligation under the Labor Code. The preconditions for bargaining were present, and the Company's conduct demonstrated a clear violation of the duty to bargain in good faith. The NLRC's decision was a valid exercise of its power to resolve labor disputes through compulsory arbitration. On the alleged denial of procedural due process: The Court found that the Company's claim of denial of due process was bereft of legal and factual support. The Company had been granted various postponements and had consistently failed to respond to the Union's requests for negotiation and counter-proposals. Its overall behavior, including stalling tactics during arbitration, demonstrated a lack of good faith and a disregard for the policy of expediting labor dispute settlements. The Court held that such schemes and dubious maneuvers should not be countenanced. On the finding of unfair labor practice for refusal to bargain: The Court affirmed the NLRC's pronouncement that the Company was guilty of unfair labor practice. It was established that the Union was a duly certified bargaining agent, made definite requests to bargain accompanied by a proposed CBA which were left unanswered, and the Company made no counter-proposals. This totality of conduct conclusively indicated a lack of sincere desire to negotiate. The Court cited jurisprudence holding that a company's refusal to make counter-proposals, especially when left unanswered, may indicate bad faith. On the reasonableness and legal basis of the adopted CBA: The Court was not persuaded by the Company's argument that the adopted CBA was a nullity for lack of consent or that its implementation would lead to the company's closure. The Court noted that such arguments and supporting evidence should have been presented before the Labor Arbiter, the proper forum. The NLRC, under PD 873, as amended, is authorized to determine the reasonableness of the terms and conditions of employment in a CBA, and its findings on reasonableness are accorded due respect.
Main Doctrine
An employer's unjustified refusal to bargain in good faith, characterized by a consistent disregard of the union's requests for negotiation and counter-proposals, constitutes unfair labor practice. The NLRC may declare a proposed collective bargaining agreement as the governing agreement if it finds it reasonable, especially after conciliation and arbitration efforts have failed.