Pamantasan Ng Lungsod Ng Maynila v. Civil Service Commission
REITERATIONFacts
The Antecedents: Sixteen (16) full-time instructors of Pamantasan ng Lungsod ng Maynila (PLM), holding temporary, yearly renewable contracts, were informed of the non-renewal of their appointments for the school year 1990-1991. These instructors were members of the Pamantasan Ng Lungsod Ng Maynila Faculty Organization (PLMFO). They filed a complaint for illegal dismissal and unfair labor practice against PLM and its officers with the Civil Service Commission (CSC). Procedural History: The CSC referred the case to the Public Sector Labor-Management Council (PSLMC). The PSLMC, after hearing, found PLM guilty of Unfair Labor Practice and ordered the reinstatement of the complainants. PLM's motion for reconsideration was denied. PLM filed a petition for certiorari with the Supreme Court (G.R. No. 105157), which was dismissed for failure to submit the required certification on forum-shopping and later became final and executory. Subsequently, the CSC, acting on the PSLMC's resolution, directed PLM to reinstate the employees with back salaries. PLM's motion for reconsideration was denied by the CSC. The Petition: PLM filed a petition for certiorari with the Supreme Court, alleging that the CSC acted with grave abuse of discretion by adopting the PSLMC's findings without affording PLM an opportunity to be heard, thereby denying it due process. PLM also argued that the CSC erred in ordering reinstatement and backwages for employees whose temporary contracts had expired.
Issue(s)
Whether the Civil Service Commission acted with grave abuse of discretion tantamount to lack of jurisdiction and denial of due process when it adopted the findings of the Public Sector Labor-Management Council without conducting its own hearing. Whether the Civil Service Commission committed a grave abuse of discretion in directing reinstatement and payment of backwages to private respondents whose temporary contracts of employment had already expired; and whether the non-renewal of temporary employment contracts of faculty members who are active in a faculty organization constitutes illegal dismissal and unfair labor practice.
Ruling
The petition for certiorari is DISMISSED. The assailed resolutions of the Civil Service Commission are AFFIRMED. The temporary restraining order issued by this Court is LIFTED.
Ratio Decidendi
On the issue of grave abuse of discretion and denial of due process: The Court held that the Civil Service Commission did not act with grave abuse of discretion. While the CSC and PSLMC exercise quasi-judicial functions, the issues of unfair labor practice and illegal dismissal in this case were unavoidably interlinked. The PSLMC conducted its proceedings in accordance with its mandate, and its conclusion regarding PLM's unfair labor practice was already deemed final and executory in a previous Supreme Court resolution (G.R. No. 105157). The CSC, in adopting the PSLMC's findings, was acting on the case forwarded to it for appropriate action, which included reinstatement. The Court reiterated that 'due process' affords an opportunity to be heard, not necessarily an actual hearing, and PLM had opportunities to present evidence before the PSLMC but failed to do so. Therefore, PLM could not complain of denial of due process. On the issue of reinstatement and backwages for temporary employees; and whether the non-renewal constituted illegal dismissal and unfair labor practice: The Court affirmed that while the non-renewal of temporary employment contracts is ordinarily a management prerogative, this rule must yield to the superior constitutional right of employees to self-organization. The Court found sufficient evidence that PLM's decision not to renew the contracts was motivated by the faculty members' union activities, constituting union busting. Therefore, the termination, even of temporary employees, was for an illegal cause, making the dismissal illegal and justifying reinstatement with back salaries. The Court emphasized that the constitutional right to self-organization is superior to the management’s right not to renew temporary appointments when the exercise of discretion is calculated to bust the union. The Court found that PLM committed Unfair Labor Practice. The PSLMC's findings, which were adopted by the CSC, indicated that PLM management did not renew the appointments of active PLMFO members despite their qualifications and impressive performance. Furthermore, PLM failed to produce evidence to justify the non-renewal, relying solely on the temporary nature of the contracts. The PSLMC noted that some replacements had lesser qualifications, and PLM refused to produce evaluation results, suggesting these would be detrimental to its case. The Court concluded that the charges for non-renewal were either false or untenable, and the circumstances showed that these charges were created to mask PLM's real motivation, which was to abridge the employees' constitutional right to self-organization.
Main Doctrine
The exercise of management prerogative to not renew temporary employment contracts may be deemed illegal if motivated by union busting activities, thereby infringing upon the constitutional right to self-organization, which is superior to the right of management in such instances.