Hongkong and Shanghai Banking Corporation Employees Union v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: The Hongkong and Shanghai Banking Corporation Employees Union (petitioner union) staged a strike against The Hongkong and Shanghai Banking Corporation Limited (respondent bank) due to the bank's alleged arbitrary reduction of CBA-established entry-level clerical pay rates and refusal to bargain collectively on wage rates. The strike involved acts of barricading and obstructing ingress to and egress from the bank's offices. Procedural History: The respondent bank filed a petition for injunction with the National Labor Relations Commission (NLRC), seeking to enjoin the petitioner union's obstructive actions. The NLRC granted a temporary restraining order and subsequently, after proceedings including the reception of evidence, issued a writ of preliminary injunction. The NLRC denied the petitioner union's oral motion to dismiss and directed further hearings for a permanent injunction. The Petition: The petitioner union filed a petition for certiorari with the Supreme Court, assailing the NLRC's resolution. The union argued that the NLRC gravely abused its discretion by denying its motion to dismiss, contending the bank's petition for injunction failed to specifically allege the requisites under Article 218(e) of the Labor Code. The union also claimed a denial of due process, asserting it was not given the opportunity to cross-examine witnesses regarding excluded evidence and to present its own evidence in opposition.
Issue(s)
Whether the NLRC acted with grave abuse of discretion in denying the petitioner union's motion to dismiss and granting the respondent bank's prayer for a writ of preliminary injunction. Whether the NLRC deprived the petitioner union of due process.
Ruling
The petition is devoid of merit and is DISMISSED.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the motion to dismiss and granting the preliminary injunction: The Supreme Court held that the petitioner union failed to show grave abuse of discretion on the part of the NLRC. The Court clarified that it is not necessary for the respondent bank to allege verbatim the requisites for the issuance of a temporary restraining order and/or writ of preliminary injunction under Article 218(e) of the Labor Code. The Court found that the bank's original and supplemental petitions contained sufficient allegations that union members were unlawfully obstructing ingress and egress, disrupting operations, and causing continuing damage. These allegations were deemed proven by the respondent bank during the proceedings for the preliminary injunction. The Court reiterated that its function in a certiorari proceeding is limited to reviewing issues of jurisdiction or grave abuse of discretion, not to review findings of fact, as it is not a trier of facts. Therefore, the NLRC's action in giving due course to the petition and issuing the injunction was not attended by grave abuse of discretion. On the issue of denial of due process: The Supreme Court found the petitioner union's contention of being deprived of due process unavailing. The Court noted that during the proceedings before the NLRC, the petitioner union's counsel, instead of cross-examining the bank's witnesses, opted to resort to oral argument and moved for dismissal based on insufficiency of evidence. The respondent bank opposed this motion, and the incident was submitted for resolution. The NLRC had no alternative but to decide based on the evidence presented. Furthermore, the NLRC did provide an opportunity for the petitioner union to controvert the bank's evidence by directing the Labor Arbiter to receive evidence. Thus, the NLRC did not commit any grave abuse of discretion in its handling of the proceedings.
Main Doctrine
The NLRC did not commit grave abuse of discretion in granting a preliminary injunction against a union obstructing ingress and egress during a strike, as the bank's petition sufficiently alleged grounds under Article 218(e) of the Labor Code and the obstruction caused grave and irreparable damage.