Castro v. Philippine Long Distance Telephone Company
REITERATIONFacts
The Antecedents: Respondents Philippine Long Distance Telephone Company (PLDT) dismissed ninety-four (94) union officers and members, including petitioners, for participating in a strike declared illegal. The dismissals were initially upheld by the National Labor Relations Commission (NLRC) and subsequently by the Supreme Court. However, during the pendency of the case before the NLRC, the striking employees were readmitted to work, subject to the outcome of the case. Later, PLDT offered some of these employees redundancy/early retirement programs and promotions, which the employees argued constituted a waiver or condonation of their previous misconduct, rendering the dismissal resolutions moot. PLDT denied this, asserting res judicata. Procedural History: The Labor Arbiter initially ruled the dismissals illegal, finding PLDT's subsequent actions as condonation. This decision was appealed to the NLRC, which reversed the Labor Arbiter, finding insufficient proof of waiver. The NLRC awarded financial assistance to some employees. Both parties appealed to the Court of Appeals (CA). Separately, a new Collective Bargaining Agreement (CBA) was signed, granting P133,000.00 to each PLDT employee. Labor Arbiter Reyno ordered PLDT to pay this amount to the affected employees, deeming it accrued prior to the NLRC's reversal. The NLRC sustained this order. However, the CA vacated the NLRC decision, ordering the petitioners to return the P133,000.00, finding they were no longer employees at the time of the CBA signing and thus not entitled to its benefits. The Petition: Petitioners seek review of the CA's decision, arguing they are entitled to the P133,000.00 benefit because the CBA became effective on November 9, 2000, prior to the NLRC's December 28, 2000 decision that declared their dismissal valid. Respondents contend that the CBA was finalized on March 14, 2001, by which time petitioners were no longer employees or members of the bargaining unit, making the benefit grant unjust enrichment. The Supreme Court, in this Resolution, affirms the CA's ruling, holding that petitioners were no longer employees of PLDT nor members of the bargaining unit when the CBA was signed or became effective, and therefore, are not entitled to its benefits.
Issue(s)
Whether petitioners, who were terminated for cause and whose dismissals were upheld by final judgment, are entitled to benefits under a new Collective Bargaining Agreement (CBA) that became effective after their termination. Whether the acts of PLDT in granting early retirement/redundancy benefits and promotions to some employees constituted supervening events amounting to a waiver or condonation of the illegality of the strike, thereby rendering the prior judgments moot.
Ruling
The petition is bereft of merit. The Court affirmed the Court of Appeals' ruling, directing each petitioner to return the amount of P133,000.00 they received. Dispositive Portion: The assailed November 24, 2009 Decision and March 25, 2010 Resolution of the Court of Appeals in CA-GR. SP No. 72889 are hereby AFFIRMED.
Ratio Decidendi
On the entitlement to CBA benefits: The Court reiterated the settled rule that the benefits of a CBA extend only to laborers and employees who are members of the collective bargaining unit. In this case, the Supreme Court's August 3, 1998 Resolution, which upheld the petitioners' dismissal for participation in an illegal strike, became final on January 18, 1999. PLDT subsequently notified them of their termination for cause based on this final judgment. Although the employees claimed supervening events, the Court, in a subsequent resolution (January 16, 2006 in G.R. Nos. 170607-08), ruled out the presence of such events. Therefore, the termination of petitioners' employment with PLDT must be reckoned from January 18, 1999. Consequently, petitioners were no longer employees of PLDT nor members of the collective bargaining unit represented by MKP when the CBA was signed on March 14, 2001, or when it became effective on November 9, 2000. As such, they are not entitled to avail of the benefits under the new CBA. The Court found no reversible error on the part of the CA in directing the return of the P133,000.00. On the claim of supervening events (waiver/condonation): The Court, in its Resolution dated January 16, 2006 in G.R. Nos. 170607-08, had already ruled out the presence of supervening events that would evince an intent on the part of PLDT to waive or condone the effects of the illegal strike. This prior ruling, having attained finality, bars the re-litigation of this issue under the principle of res judicata. The acts of granting benefits or promotions prior to the finality of the dismissal judgment were not considered sufficient to nullify the consequences of the illegal strike as determined by the Court.
Main Doctrine
Employees terminated for cause, whose dismissals were upheld by final judgment, are not entitled to benefits under a new Collective Bargaining Agreement (CBA) that was signed and became effective after their termination, as they are no longer members of the bargaining unit.