Philippine Metal Foundries Inc. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Philippine Metal Foundries, Inc. (petitioner) charged the Regal Manufacturing Employees Association (REGEMAS) and its members (private respondents) with unfair labor practice for declaring a strike on October 5, 1963, without filing a notice of strike, despite a 'no strike, no lockout' clause and a grievance procedure in their collective bargaining agreement (CBA). The Union denied the charge, alleging that the company refused a grievance conference request and instead dismissed the Union President, Celestino Baylon, violating the CBA. In a separate case, private respondents charged petitioner and its General Manager with unfair labor practice for dismissing Baylon on October 3, 1963, allegedly due to his union activities. Petitioner countered that Baylon was dismissed for habitual absences and for abetting the illegal strike. Procedural History: The Court of Industrial Relations (CIR) jointly tried both cases and found that Baylon was discharged for union activities and that the employees struck in good faith belief that Baylon's dismissal was an unfair labor practice. The CIR found petitioner and its manager guilty of unfair labor practice in dismissing Baylon, ordered his reinstatement with back wages, and dismissed petitioner's charge of unfair labor practice against the Union. The CIR en banc denied petitioner's motion for reconsideration. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, raising issues on whether Baylon's dismissal was due to absences or union activities, and whether the strike was legal.
Issue(s)
Whether Celestino Baylon was dismissed due to his absences or to his union activities as Union President. Whether the strike declared by the Union on October 5, 1963, is legal or not.
Ruling
The petition for certiorari is DISMISSED. The decision of the Court of Industrial Relations finding Philippine Metal Foundries, Inc. guilty of unfair labor practice in dismissing Celestino Baylon and declaring the strike legal is affirmed.
Ratio Decidendi
On the issue of whether Celestino Baylon was dismissed due to his absences or to his union activities: The Court affirmed the CIR's finding that Baylon was dismissed due to his union activities, not solely for absences. While Baylon had incurred numerous absences, the company's failure to dismiss him earlier, particularly in March 1963 when he had twelve consecutive unexcused absences, indicated that these infractions were previously disregarded. The timing of his dismissal, occurring just two hours after he submitted a written explanation for his absences and invited the General Manager to a grievance conference, strongly suggested that his union activities, specifically his representation of union members, were the ultimate trigger. The Court emphasized that even if a lawful cause for discharge exists, it is no defense if the employee was actually discharged for union activity. The CIR's finding, based on substantial evidence, that the dismissal was tainted with unfair labor practice was upheld. On the issue of whether the strike declared by the Union on October 5, 1963, is legal or not: The Court ruled that the strike was legal. The employees had a valid reason to strike in the belief that Baylon's dismissal constituted an unfair labor practice. The Court clarified that it is sufficient if labor entertains a good faith belief that an unfair labor practice has been committed, as this can be the inducing factor for staging a strike. Therefore, the strike did not violate the 'no strike' clause of the CBA because it was a response to the employer's unfair labor practice. Furthermore, the Court noted that a 'no strike' clause is generally applicable only to economic strikes. The strike was also not illegal for lack of notice, as a strike notice is not required in cases arising from an employer's unfair labor practices, due to the urgent necessity and the nature of the strike being against practices condemned by public policy.
Main Doctrine
A strike declared by employees in the good faith belief that the dismissal of their union president was an unfair labor practice is not illegal, even if the belief is not factually correct, and does not violate a 'no strike' clause, especially when the dismissal itself is found to be an unfair labor practice. A notice of strike is not necessary in cases of strikes arising from unfair labor practices.