Social Security System Employees Association v. Court of Appeals
NEW DOCTRINEFacts
1. The Antecedents: The Social Security System (SSS) filed a complaint against the Social Security System Employees Association (SSSEA) and its officers, alleging that the SSSEA staged an illegal strike on June 9, 1987, barricading the SSS Building, preventing non-striking employees from working, and disrupting services for SSS members. The SSS sought an injunction to stop the strike, an order for the strikers to return to work, and damages. The strike was initiated by the SSSEA due to the SSS's alleged failure to act on demands including the implementation of a collective bargaining agreement, payment of overtime and holiday pay, regularization of contractual employees, and addressing alleged discrimination and unfair labor practices. 2. Procedural History: The Regional Trial Court (RTC) of Quezon City issued a temporary restraining order against the strike. The SSSEA moved to dismiss, arguing the RTC lacked jurisdiction. The RTC denied the motion to dismiss and converted the restraining order into a preliminary injunction, finding the strike illegal. After the RTC denied a motion for reconsideration, the SSSEA filed a petition for certiorari and prohibition with preliminary injunction with the Supreme Court (G.R. No. 79577). The Supreme Court referred the case to the Court of Appeals. The Court of Appeals subsequently issued a decision, and after the Supreme Court denied the SSSEA's motion for reconsideration in G.R. No. 79577, the instant petition for review of the Court of Appeals' decision was filed. 3. The Petition: The petitioners, SSSEA and its officers, argue that the RTC lacked jurisdiction to enjoin the strike and order employees back to work, contending that such labor disputes fall under the exclusive jurisdiction of the Department of Labor and Employment or the National Labor Relations Commission. They also filed a separate petition/application for preliminary and mandatory injunction seeking to compel the SSS to pay withheld bonuses and benefits, attaching a Civil Service Commission order affirming the entitlement of certain officers to these benefits. The Supreme Court affirmed the Court of Appeals' decision, holding that SSS employees, as government employees, do not have the right to strike and that the RTC had jurisdiction to issue the injunction. The Court also denied the separate petition for injunction regarding bonuses and benefits, deeming it extraneous to the main issue and suggesting the petitioners pursue execution of the Civil Service Commission order.
Issue(s)
Whether the Regional Trial Court can enjoin the Social Security System Employees Association (SSSEA) from striking and order the striking employees to return to work; and whether employees of the Social Security System (SSS) have the right to strike. Whether the Regional Trial Court has jurisdiction to hear the case initiated by the SSS and to enjoin the strikers from continuing with the strike and to order them to return to work. On the Petition/Application for Preliminary and Mandatory Injunction.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, denying the petition for review. It held that SSS employees, as government employees, do not have the right to strike, and the Regional Trial Court has jurisdiction to issue injunctions against such illegal strikes.
Ratio Decidendi
On the right to strike of SSS employees and the RTC's authority to enjoin the strike: The Court ruled that employees of the SSS do not have the right to strike. While the 1987 Constitution guarantees the right to self-organization, collective bargaining, and peaceful concerted activities for all workers, including government employees, it is silent on the right to strike for public sector employees. The intent of the framers of the Constitution was to limit the right of government employees to self-organization only, not to include the right to strike. This interpretation is consistent with historical legislation. The terms and conditions of employment for government employees are governed by the Civil Service Law and rules. Memorandum Circular No. 6, s. 1987 of the Civil Service Commission enjoins all government officers and employees from staging strikes. Therefore, the strike staged by the SSS employees was illegal. The Court held that the Regional Trial Court (RTC) has jurisdiction to enjoin the illegal strike staged by SSS employees because the terms and conditions of employment for government employees are governed by the Civil Service Law, not the Labor Code. The Public Sector Labor-Management Council has not been granted the authority to issue writs of injunction. Consequently, resort to the general courts of law, such as the RTC, for the issuance of an injunction to restrain an illegal strike by government employees is appropriate. On the jurisdiction of the Regional Trial Court: The petitioners' assertion that the dispute falls under the exclusive jurisdiction of the NLRC is incorrect. Executive Order No. 180 vests the Public Sector Labor-Management Council with jurisdiction over unresolved labor disputes involving government employees. The RTC acted with caution by issuing the injunction to prevent disruption of public service and admonishing the parties to refer unresolved controversies to the Public Sector Labor-Management Council. On the Petition/Application for Preliminary and Mandatory Injunction: The Court denied the petitioners' separate application for a writ of preliminary prohibitive and mandatory injunction concerning withheld bonuses and benefits. It noted that this matter was extraneous to the issues elevated to the Supreme Court and that the petitioners' remedy was to cause the execution of the Civil Service Commission order dated May 5, 1989, if it had become final, rather than petitioning the Supreme Court for an injunction.
Main Doctrine
Employees of the Social Security System (SSS), being part of the civil service, are prohibited from striking. Regional Trial Courts have jurisdiction to issue injunctions against illegal strikes by government employees.