Master Iron Labor Union v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: The Master Iron Labor Union (MILU) and Master Iron Works Construction Corporation (Corporation) entered into a three-year collective bargaining agreement (CBA) effective December 1, 1986. The CBA included provisions against strikes and lockouts, and stipulated service allowances and transportation for workers assigned outside the company plant. Shortly after signing, the Corporation began subcontracting work typically done by regular employees, leading to a reduced work schedule for MILU members, with workers only getting ten days of work per month. MILU's requests to address this through the CBA's grievance procedure were ignored by the Corporation. 2. Procedural History: MILU filed a notice of strike on April 8, 1987, due to alleged CBA violations, discrimination, suspension of union officials, and refusal to entertain grievances. An initial agreement with the Department of Labor and Employment (DOLE) to restore work to regular employees was not honored by the Corporation. Following the suspension of a union president for insubordination and continued subcontracting, MILU filed another notice of strike on July 9, 1987. A strike commenced on July 24, 1987, which was later dispersed by CAPCOM soldiers. The Corporation filed a petition to declare the strike illegal. MILU re-staged the strike and subsequently offered to return to work. The Labor Arbiter declared the strike illegal and ordered the termination of individual petitioners. The National Labor Relations Commission (NLRC) affirmed the illegality of the strike and termination of employment but modified the decision by deleting the cancellation of the union's registration and the award of attorney's fees. MILU's motion for reconsideration was denied. 3. The Petition: Petitioners seek certiorari to annul the NLRC's decision, arguing that the strike was legal because it was based on unfair labor practices, not economic issues, thus not violating the CBA's no-strike clause. They contend the NLRC erred in finding a failure to exhaust the grievance procedure, as the Corporation ignored their requests for meetings. Petitioners also claim bias due to the dismissal of criminal charges against strikers while they faced labor charges, and that the NLRC wrongly deemed their offer to return to work conditional. They assert that the Corporation's subcontracting practices constituted a violation of the CBA and unfair labor practice, and that the intervention of CAPCOM soldiers was illegal.
Issue(s)
Whether the strike staged by MILU was illegal in view of the no-strike clause in the Collective Bargaining Agreement (CBA). Whether the dispersal of the picket line by CAPCOM soldiers was lawful under the Labor Code. Whether the offer to return to work made by the union was conditional, thereby justifying the refusal to reinstate.
Ruling
The Supreme Court set aside the questioned decision and resolution of the NLRC and the decision of the Labor Arbiter. It ordered the reinstatement of the individual petitioners with three years' backwages and without loss of seniority rights and other privileges. The respondent corporation was also ordered to desist from subcontracting work usually performed by its regular workers.
Ratio Decidendi
On Issue 1: The Court ruled that a no-strike clause in a Collective Bargaining Agreement (CBA) applies only to economic strikes, which are defined as strikes intended to force concessions from the employer that are not legally required. Applying Philippine Metal Foundries, Inc. v. CIR, the Court emphasized that if a strike is founded on an Unfair Labor Practice (ULP), it cannot be considered a violation of a no-strike clause. The grounds for MILU's strike—specifically the violation of CBA provisions regarding service allowances, discrimination, and the unreasonable suspension of union officials—constitute ULPs under Article 248 of the Labor Code. Even if the allegations of ULP are subsequently found to be untrue, the strike remains legal under the 'good faith' doctrine if the union honestly believed the employer committed such acts. Therefore, the petitioners' strike was legal as it was a protest against what they perceived in good faith as the Corporation's bad faith in bypassing the CBA through subcontracting. On Issue 2: The Court found the intervention of CAPCOM soldiers in the picket line to be a violation of Article 264(d) of the Labor Code. This provision mandates that the police force must keep out of picket lines unless actual violence or other criminal acts occur. The Labor Arbiter's own findings showed that there was no pervasive or widespread coercion or violence perpetrated by the strikers that would warrant the presence of the military. Under the ruling in Shell Oil Workers' Union v. Shell Company of the Philippines, Ltd., the Court held that responsibility for isolated acts of force during a strike should be individual rather than collective. Since the strike was not violent in character by policy, the unauthorized dispersal by CAPCOM did not render the strike illegal. On Issue 3: The Court rejected the NLRC's finding that the union's offer to return to work was 'conditional.' A plain reading of the letter sent by the union president, Wilfredo Abulencia, revealed no conditions; the statement regarding 'continuing talks' for a peaceful relationship was merely a reference to the grievance procedure. Grievance procedures are a continuous part of collective bargaining intended to maintain industrial peace through dialogue. The Corporation's refusal to heed the request for a grievance procedure demonstrated its own lack of intent to abide by the CBA. Consequently, the strike being legal, the employees were entitled to reinstatement, and the offer to return should have been accepted by the employer.
Main Doctrine
A strike founded on an employer's unfair labor practice is not a violation of a no-strike clause in a Collective Bargaining Agreement (CBA). The no-strike clause is applicable only to economic strikes.