National Federation of Labor v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners, the National Federation of Labor (NFL) and 141 members, are dismissed employees of respondent PERMEX Producer and Exporter Corporation. NFL alleged that 10 union officials were barred from entering company premises on January 23, 1993, due to union activities. PERMEX contended these workers were given time off for union activities and were not disciplined for union affiliation but for breach of company policy regarding undertime and absences. On January 25, 1993, workers attempted to re-enter the premises but were prevented, leading to a picket that barricaded the gates, trapping workers inside and paralyzing operations. Non-striking workers were also prevented from working. A Memorandum of Agreement was forged on January 27, 1993, leading to workers' return, but most refused to submit explanations for their participation in the strike, resulting in preventive suspension. On January 29, 1993, NFL filed a Notice of Strike, followed by a new Notice on February 5, 1993, alleging discrimination, coercion, union busting, intimidation, and dismissal. PERMEX filed a case to declare the January 25-26 strike illegal. On February 11, 1993, NFL-affiliated workers barricaded company gates again, preventing ingress and egress. The company had to ferry workers via motorboats until March 2, 1993, when strikers cut the fence to the wharf and chained it. Acts of coercion, intimidation, and threats were allegedly committed by strikers. The Secretary of Labor assumed jurisdiction on March 11, 1993, and issued a Return-to-Work Order, which was ignored by the workers until March 29, 1993. Procedural History: Labor Arbiters Reynaldo Villena and Allen Abubakar rendered consolidated decisions declaring the strikes illegal, dismissing the unfair labor practice complaint against PERMEX, and awarding damages to PERMEX. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiters' decision but modified the damages awarded to PERMEX. NFL's motion for reconsideration was denied. The Petition: Petitioners contend that the NLRC committed grave abuse of discretion by disregarding their evidence, failing to conduct open hearings, upholding the dismissal of employees based on a prima facie finding by the City Fiscal's Office, and relying on unverified "company internal reports" for damages.
Issue(s)
Whether the NLRC committed grave abuse of discretion in its findings of fact and procedure. Whether the strikes staged by the petitioners were illegal. Whether the dismissal of the 141 employees was valid. Whether the damages awarded to PERMEX were supported by competent evidence.
Ruling
The petition is dismissed for lack of merit. The Supreme Court affirmed the decision of the National Labor Relations Commission.
Ratio Decidendi
On the NLRC's alleged grave abuse of discretion and procedural issues: The Supreme Court reiterated that a petition for certiorari under Rule 65 is limited to reviewing grave abuse of discretion or acts without or in excess of jurisdiction, not the correctness of evidence evaluation. The Court held that findings of fact by the NLRC, when supported by evidence, are accorded respect and finality. Furthermore, a formal trial-type hearing is not always essential to due process; parties must be afforded a fair opportunity to explain their side, which the petitioners had through affidavits and position papers. The holding of a trial is discretionary for the labor arbiter and not a matter of right. The Court emphasized that findings of administrative agencies, like the NLRC, are binding on the Supreme Court if supported by substantial evidence. On the illegality of the strikes: The Court found that the strikes staged on January 25-26, 1993, and February 11 to March 29, 1993, were illegal. The strike on January 25-26 failed to comply with mandatory procedural requisites, such as filing a notice of strike and observing the cooling-off period. The strike on February 11 had only six days from the filing of the notice of strike on February 5, violating the cooling-off period. Moreover, during the February 11 strike, strikers committed illegal acts, including barricading, chaining gates, cutting fences, and intimidating non-striking workers, which are violations of Article 264(e) of the Labor Code. The Court clarified that even if the union acted in good faith, failure to comply with mandatory requirements like notice of strike and strike vote renders the strike illegal, especially after the enactment of Republic Act No. 6715. On the validity of the dismissal of employees: The Court ruled that the dismissal of the 141 workers was valid, not solely based on the prima facie finding of the City Prosecutor's Office, but principally on their refusal to return to work after the Secretary of Labor assumed jurisdiction and issued a Return-to-Work Order on March 11, 1993. The Court cited jurisprudence holding that a strike undertaken despite an assumption or certification order from the Secretary of Labor becomes a prohibited and illegal activity, leading to the forfeiture of employment status. The petitioners' claim that PERMEX imposed conditions prior to their return was unsubstantiated by evidence, as the alleged memorandum was dated prior to the return-to-work order, and no copy of a subsequent memorandum was presented. On the damages awarded to PERMEX: The Court found that the damages awarded by the NLRC were not based on concrete proof, as PERMEX submitted mere certifications of spoiled products and lost commitments, which were considered self-serving and of no probative value by the Labor Arbiter. However, acknowledging that the prolonged strike undoubtedly caused injury, the Court awarded nominal damages of P300,000.00 to PERMEX. The Court explained that nominal damages are awarded to vindicate a right that has been violated, not necessarily to indemnify for actual loss, in the absence of competent proof of actual damages suffered.
Main Doctrine
Strikes must strictly comply with mandatory procedural requirements, including notice of strike, cooling-off period, strike vote, and notice to the NCMB, to be considered legal. Failure to comply renders the strike illegal, and participation in such an illegal strike, especially after a return-to-work order, can lead to forfeiture of employment.