Insular Life Assurance Co. v. Insular Life Assurance Co.
REITERATIONFacts
The Antecedents: The case involves a motion for reconsideration filed by respondents The Insular Life Assurance Co., Ltd., FGU Insurance Group, and Jose M. Olbes, questioning the Supreme Court's decision dated January 30, 1971. Respondents alleged that the Court improperly reviewed and revised the factual findings of the Court of Industrial Relations (CIR), disregarding voluminous documentary and testimonial evidence they presented. Procedural History: The Supreme Court, in its January 30, 1971 decision, had reversed factual findings of the CIR, deeming them unsupported by substantial and credible evidence. The respondents sought reconsideration of this decision. The Petition: The respondents, in their motion for reconsideration, grouped their objections into three categories: (1) findings and conclusions without basis on record or contrary to evidence; (2) findings and conclusions contrary to the CIR's factual determination; and (3) issues not raised or errors not assigned by the parties. They specifically contested findings related to the creation of disturbances, dissuasion from disaffiliation, lack of counter-proposals, basis for a restraining order, number of criminal charges filed, hiring of former legal counsels, and an incident involving non-strikers entering the premises. They also objected to findings of discrimination in re-admission, dismissal without cause, denial of defense opportunities, and the content of letters sent to employees. Finally, they questioned the Court's discussion of the nature of the strike, refusal to bargain in good faith, and reclassification of employees.
Issue(s)
Whether the Supreme Court erred in reviewing and reversing the factual findings of the Court of Industrial Relations. Whether the Supreme Court's specific factual findings, as contested by the respondents, were supported by substantial and credible evidence. Whether the Supreme Court erred in discussing and resolving issues not raised or errors not assigned by the parties. Whether the policy on awarding backwages should be modified in light of subsequent jurisprudence.
Ruling
The Supreme Court denied the motion for reconsideration, affirming its January 30, 1971 decision in all other respects, but modified the ruling on backwages by fixing the award to a total equivalent of three years without qualification or deduction.
Ratio Decidendi
On the review of CIR's factual findings: The Court reiterated that while findings of fact of the CIR, if supported by substantial evidence, bind the Supreme Court, those unsupported by substantial and credible evidence do not. The Court found that the factual determinations of the CIR in this case were indeed unsupported by substantial and credible proof, justifying its review and reversal to arrive at correct conclusions regarding the parties' rights and obligations. The Court noted that the CIR's proceedings, involving multiple hearing examiners and prolonged delays, could contribute to misapprehension of facts. On specific contested factual findings: The Court meticulously addressed each of the respondents' objections. For instance, regarding the instruction to create a disturbance, the Court clarified it suggested a likelihood rather than a categorical finding. On the circular dissuading disaffiliation, the Court found the records unclear but deemed the statement immaterial. The Court found evidence supporting its finding that respondents did not make counter-proposals and insisted on dropping union security demands, citing testimonial evidence. Regarding the restraining order, the Court found it well-founded that the petition for injunction was predicated on alleged acts of violence by picketers, even if the order didn't explicitly mention pending criminal charges. The Court sustained the objection regarding the number of criminal charges, clarifying that while many were filed, the figure 'more than 120' was an overstatement, with actual charges adding up to eighty-four. On the hiring of former legal counsels, the Court found evidence of their affiliation with the Federation of Free Workers, which represented the Unions, and deemed the exact nature of their prior counsel role immaterial. Concerning the incident with non-strikers, the Court found evidence supporting Olbes leading busloads of non-strikers, though the presence of armed escorts was not clearly evinced. The Court also detailed the multiple entrances to the buildings and noted the gate measured two to three meters wide, not less than two meters. The Court found substantial and credible evidence supported its findings on discrimination in re-admission, dismissal without cause, denial of defense, and the threatening nature of the respondents' letters, which formed the basis for its conclusion of unfair labor practice. On issues not raised or errors not assigned: The Court asserted its authority to review and resolve matters not assigned as errors if essential for a just decision, especially when closely related to assigned errors or necessary for determining the raised issues. The Court found that the nature of the strike, refusal to bargain in good faith, and reclassification of employees were closely related to the determination of unfair labor practice and thus necessary to resolve. On the modification of backwages award: The Court acknowledged significant changes in jurisprudence regarding backwages, citing Mercury Drug Co. vs. CIR and Feati University Club vs. Feati University. These cases established a policy of fixing backwages to a reasonable level, often three years, without qualification or deduction to avoid protracted delays and ensure prompt satisfaction of awards. Considering the eighteen years that had elapsed since the commencement of backwages and the procedural delays, the Court deemed it applicable and justified to limit the backwages award to three years without qualification or deduction.
Main Doctrine
The Supreme Court may review and reverse findings of fact of the Court of Industrial Relations if such findings are unsupported by substantial and credible evidence. The Court also clarified the policy on awarding backwages, fixing it at three years without qualification or deduction.