Soriano v. Atienza
REITERATIONFacts
The Antecedents: The petitioners, ten employees of Shellwood Industries Philippines Incorporated, were dismissed from their employment. This dismissal followed a request from Concepcion Nuguid, who claimed to be the union president, to terminate their services based on a union security clause in the collective bargaining agreement. The petitioners had been expelled from the union, Samahan ng Malayang Manggagawa sa Shellwood Industries, in a meeting conducted by Nuguid. Procedural History: The petitioners filed a complaint for illegal dismissal, unfair labor practice, and moral damages against Shellwood Industries, its president Ramon Panique, and former union president Concepcion Nuguid. The Labor Arbiter ordered the company to reinstate the complainants without backwages but directed the company to provide financial assistance equivalent to six months' salary. Upon appeal by the respondents, the National Labor Relations Commission (NLRC) affirmed the reinstatement order but deleted the award of financial assistance, finding no legal or factual basis for it. The Petition: The petitioners filed a special civil action for certiorari with the Supreme Court, challenging the NLRC's deletion of the financial assistance award. They argue that the company had knowledge of Nuguid's lack of authority to act as union president and thus participated in their illegal dismissal through negligence. The petitioners contend that the company should be liable for financial assistance to compensate for their suffering. The petition specifically imputes grave abuse of discretion to the NLRC solely on the issue of deleting the financial assistance.
Issue(s)
Whether the NLRC gravely abused its discretion in deleting the award of financial assistance. Whether the company acted in good faith in dismissing the petitioners.
Ruling
The petition is dismissed. The NLRC did not commit grave abuse of discretion in deleting the award of financial assistance.
Ratio Decidendi
On the issue of grave abuse of discretion by the NLRC: The Court held that the NLRC did not commit grave abuse of discretion. The petitioners' claim of grave abuse of discretion was limited to the NLRC's act of setting aside the financial assistance award. The NLRC's finding of good faith on the part of the company was based on substantial evidence, which is conclusive upon the Court. The NLRC correctly noted that the company was compelled to dismiss the petitioners based on the request of the union president, pursuant to the clear terms of the CBA, which is considered the law between the contracting parties. The NLRC also considered a petition signed by a majority of workers supporting Nuguid and the lack of opposition from the new union leadership or federation, which provided the company with reason to believe Nuguid still represented the union or had the authority to act for it. Therefore, the NLRC's decision to delete the award of financial assistance, finding it to have no factual or legal basis, was a valid exercise of its discretion. On the issue of the company's good faith: The Court affirmed the NLRC's finding that the company acted in good faith. The NLRC's decision was categorical in stating that the company acted in good faith in terminating the services of the complainants. This was based on the union security provision of the CBA, which obligated the company to dismiss employees upon written request of the union. Despite the company having received a letter about the union's affiliation with a federation, there was also a petition signed by a majority of workers supporting Nuguid and giving her authority to solve workers' problems. Crucially, neither the steering committee nor the federation opposed Nuguid's request for termination. This lack of opposition led the company to reasonably assume that Nuguid still represented the union or had the authority to act for it, constituting an act of good faith. The Court reiterated that a company is not considered guilty of unfair labor practice if it merely complied in good faith with the request of the certified union for the dismissal of employees expelled from the union pursuant to the union security clause in the CBA.
Main Doctrine
The deletion of an award for financial assistance by the NLRC, when based on a finding of good faith by the employer in complying with a union security clause in a CBA, does not constitute grave abuse of discretion, as there is no legal or factual basis for such an award.