Diwa ng Pagkakaisa-Philippine Association of Free Labor Unions v. Inciong
REITERATIONFacts
1. The Antecedents: This case originated from two labor disputes filed in 1961 between Diwa ng Pagkakaisa-PAFLU (DIWA), a labor union, and Filtex International Corporation (FILTEX), a textile company. In one case, DIWA accused FILTEX of unfair labor practice for refusing work to its officers and members due to alleged union activities, seeking reinstatement with full backwages. In the other case, FILTEX charged DIWA and its members with unfair labor practice for staging an illegal strike in violation of their collective bargaining agreement. 2. Procedural History: The Court of Industrial Relations (CIR) initially declared the strike illegal and terminated the status of those responsible, ordering the reinstatement of all other employees. DIWA appealed to the Supreme Court (SC) seeking reinstatement and backwages for union officers, while FILTEX opposed. The SC, in a 1972 decision, found no reason to consider the work stoppage an illegal strike and modified the CIR decision, ordering the reinstatement of union officers with backwages. The case was remanded to the CIR for computation. Subsequent proceedings involved the National Labor Relations Commission (NLRC) and the Secretary of Labor, with various orders and appeals concerning the computation and award of backwages for both officers and members, leading to conflicting rulings on the scope of the backwage awards. 3. The Petition: This petition for certiorari under Rule 65 of the Rules of Court seeks to nullify the Order of the Acting Secretary of Labor dated June 22, 1977. The Acting Secretary had set aside a previous CIR Order of October 9, 1974, which directed the computation of backwages for DIWA members, ruling that the CIR had expanded the Supreme Court's decision by including employees not contemplated in the SC's award. DIWA argues that the Acting Secretary committed grave abuse of discretion by limiting the backwage award solely to union officers and by failing to rule on the backwages for certain officers, thereby disregarding established law and jurisprudence.
Issue(s)
Whether the Acting Secretary of Labor committed grave abuse of discretion in setting aside the CIR Order of 9 October 1974. Whether employees ordered reinstated by the CIR are entitled to backwages from the date the decision became final until they were reinstated.
Ruling
The petition is granted. The assailed Order of the Acting Secretary of Labor dated 22 June 1977 is SET ASIDE, and the Order of the CIR of 9 October 1974 is REINSTATED. Furthermore, the Resolution of the NLRC of 5 October 1976 is AFFIRMED, subject to the modification that the reduction of the computed backwages of union officers Erlinda de Leon, Ismael Dionisio and Celso Santiago is SET ASIDE.
Ratio Decidendi
On the issue of grave abuse of discretion by the Acting Secretary of Labor: The Court held that the Acting Secretary of Labor committed grave abuse of discretion amounting to lack of jurisdiction. The CIR's Order of 9 October 1974, which directed the computation of backwages and reinstatement, had become final and executory as FILTEX did not appeal this specific order to the Secretary of Labor. The subsequent appeal by FILTEX to the Secretary of Labor concerned the Labor Arbiter's Order of 30 September 1975 regarding partial execution and the issue of due process, not the merits of the CIR's 9 October 1974 Order itself. Therefore, the Acting Secretary of Labor acted beyond his authority when he partially set aside the CIR Order, particularly the award of backwages to union members, on the ground that it expanded the tenor of the Supreme Court's decision. The Supreme Court reiterated that the reinstatement portion of the CIR decision of 29 August 1964 became final and executory ten (10) days after its promulgation, and employees should have been reinstated by 9 September 1964, entitling them to backwages from that date until actual reinstatement, unless suspended. The Court found no justification for the Acting Secretary's action in expanding the scope of the Supreme Court's decision, as the CIR's order was merely implementing its own final and executory decision regarding reinstatement and backwages for those not found responsible for the strike. On the entitlement to backwages: The Court ruled that the reinstatement portion of the CIR decision of 29 August 1964 became final and executory ten (10) days after its promulgation, meaning by 9 September 1964. Consequently, employees ordered reinstated should have been reinstated by this date and are entitled to backwages from 9 September 1964 until their actual reinstatement. This entitlement applies to all employees ordered reinstated, except those who remained suspended by virtue of a CIR declaration. The Court clarified that since it did not declare the work stoppage a strike, those who remained suspended should also be reinstated, but their reinstatement would only be effective from the finality of the Supreme Court's decision in G.R. Nos. L-23960-61. The Court found that the CIR acted correctly in issuing the Order of 9 October 1974 to compute these backwages. Furthermore, the Court found the NLRC en banc's Resolution of 5 October 1976 to be arbitrary in reducing the computed backwages for three union officers by 30%, stating there was no acceptable justification for such a reduction. Therefore, the NLRC committed grave abuse of discretion in imposing this reduction, and the Supreme Court set it aside.
Main Doctrine
The Acting Secretary of Labor committed grave abuse of discretion in setting aside the Court of Industrial Relations' Order directing the computation of backwages for union members, as the said order had become final and executory and the subsequent appeal by the company did not raise the issue of backwages for members. The Supreme Court reinstated the CIR Order and affirmed the NLRC Resolution, setting aside the reduction of backwages for union officers.