Filipino Pipe and Foundry Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Respondent National Labor Union-Trade Union Congress of the Philippines (NLU-TUCP), through its national president Atty. Eulogio Lerum, filed a notice of strike on February 10, 1986, against petitioner Filipino Pipe and Foundry Corporation, alleging union busting and non-implementation of the Collective Bargaining Agreement (CBA). A conciliation conference was scheduled for March 3, 1986. However, on the morning of March 3, 1986, the local chapter, Filipino Pipe Workers Union-National Labor Union (FPWU-NLU), staged a strike which lasted until June 13, 1986. Procedural History: On April 8, 1986, petitioner filed a petition to declare the strike illegal with prayer for damages against NLU-TUCP, Atty. Lerum, and FPWU-NLU. The Labor Arbiter ruled the strike illegal and ordered NLU-TUCP to pay damages to the company, but absolved Atty. Lerum. Both parties appealed to the National Labor Relations Commission (NLRC). The NLRC reversed the Labor Arbiter's decision, dismissing the complaint against NLU-TUCP and Atty. Lerum for lack of merit. The Petition: Petitioner filed a Petition for Certiorari with the Supreme Court, assailing the NLRC's decision, arguing that the NLRC gravely abused its discretion in holding that NLU-TUCP and Atty. Lerum were not primarily responsible for the damages caused by the illegal strike.
Issue(s)
Whether the strike staged by FPWU-NLU was illegal. Whether NLU-TUCP and Atty. Eulogio Lerum are liable for damages arising from the illegal strike.
Ruling
The Supreme Court affirmed the decision of the National Labor Relations Commission, dismissing the petition for lack of merit. The strike was declared illegal, but the NLRC's ruling absolving NLU-TUCP and Atty. Lerum from liability was upheld.
Ratio Decidendi
On the Illegality of the Strike: The Court found the strike illegal for multiple reasons. Firstly, the grounds cited in the notice of strike, namely union busting and non-implementation of the CBA, were unsubstantiated. The demands concerning the P3.00 wage increase and backwages were subjects of a pending application for a writ of execution, making the strike premature. Secondly, the union failed to serve a copy of the notice of strike to the petitioner, violating Section 3 of the Implementing Rules. Thirdly, the union disregarded the mandatory thirty (30) day cooling-off period. Finally, the union staged the strike on the very day the conciliation conference was scheduled, thereby impeding the conciliation proceedings, contrary to the prohibition in Section 6 of the Implementing Rules. On the Liability of NLU-TUCP and Atty. Lerum: The Court clarified the relationship between a mother union (federation) and its local chapter (union). Citing Progressive Development Corporation vs. Secretary, Department of Labor and Employment, the Court held that the mother union acts as an agent while the local union is the principal. In this case, FPWU-NLU was the principal that staged the illegal strike, and NLU-TUCP, through its president Atty. Lerum, was merely an agent that assisted the local union. Since the liability for damages from an illegal strike falls on the principal (FPWU-NLU), and the claim against the principal was dismissed by the NLRC, the action against the agent (NLU-TUCP and Atty. Lerum) necessarily had no leg to stand on and was also correctly dismissed. The Court also noted that petitioner was estopped from questioning the status of FPWU-NLU as the bargaining representative, having recognized it for years.
Main Doctrine
A strike staged without complying with the mandatory notice and cooling-off periods, and which disrupts conciliation proceedings, is illegal. The liability for damages arising from an illegal strike primarily rests on the local union (principal) that staged it, not on the mother federation (agent) that merely assisted.