Rex Taxicab Co. v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The Rex Taxicab Company implemented new regulations for its drivers, imposing fines for various infractions, some of which were collected starting January 17, 1940. These regulations, particularly the imposition of fines, were protested by the Philippine Taxi Drivers' Union, representing the company's drivers. Despite initial negotiations and partial settlements, the drivers went on strike on January 20, 1940, following a perceived provocation during a conference. 2. Procedural History: The Secretary of Labor certified the industrial dispute to the Court of Industrial Relations (CIR) on January 22, 1940. The respondent union verbally petitioned the CIR to order the reinstatement of the striking drivers. The petitioner company objected, arguing the strike was unjustified due to alleged violence, sabotage, and the strikers' status as commission-based employees who had voluntarily left. The CIR, after hearing, found the strike justified and ordered the reinstatement of all striking employees. 3. The Petition: This case is a petition for a writ of certiorari filed by the Rex Taxicab Company, seeking to annul the CIR's order of February 1, 1940, which mandated the reinstatement of the striking drivers. The petitioner contends that the CIR erred in applying Section 19 of Commonwealth Act No. 103, in deeming the strike justified, and in failing to recognize that the strikers had either voluntarily resigned or provided just cause for their dismissal.
Issue(s)
Whether the Court of Industrial Relations (CIR) erred in ordering the reinstatement of striking drivers despite the petitioner's claim that the strike was unjustified and illegal. Whether the act of declaring a strike constitutes a voluntary renunciation of the employment relation, thereby terminating the status of the strikers as employees.
Ruling
The petition for certiorari is denied. The order of the Court of Industrial Relations is affirmed.
Ratio Decidendi
On Issue 1: The Court ruled that the Court of Industrial Relations (CIR) did not err because the strike was found to be for a justifiable purpose and carried out through peaceful means. Under Section 19 of Commonwealth Act (CA) No. 103, as amended, employees are only inhibited from striking when a dispute has been submitted to the CIR and the court has specifically enjoined them from doing so. Since the strike in this case occurred before the dispute was certified to the CIR and before any injunction was issued, it was not statutorily prohibited. The Court emphasized that it cannot interpolate stricter prohibitions into the law that the legislature did not see fit to include. The CIR found that the company's practice of imposing heavy fines to enrich itself at the expense of its drivers was 'oppressive and unjust,' providing a valid grievance for the strike. Therefore, the order for reinstatement was a proper exercise of the CIR's mandate to resolve industrial disputes through equity and justice. On Issue 2: The Court explicitly held that the declaration of a strike does not amount to a renunciation of the employment relation. Drawing from American jurisprudence such as National Labor Relations Board v. Mackay Radio & Telegraph Company, the Court affirmed that strikers remain employees during the pendency of a labor dispute. The employer-employee relationship is not severed by the mere act of quitting work as part of a collective protest against working conditions. Section 19 of Commonwealth Act (CA) No. 103 explicitly empowers the CIR to order workers back to work, which necessarily implies that they have not lost their status as employees. Furthermore, the constitutional mandate to afford protection to labor (Article XIII, Section 6, 1935 Constitution) supports the preservation of this status to allow for collective bargaining and arbitration. Consequently, the petitioner could not lawfully refuse reinstatement on the ground that the workers had already 'voluntarily' left the service.
Main Doctrine
A strike is considered justified if provoked by oppressive and unjust company regulations and penalties, and conducted peacefully. The Court of Industrial Relations has the power to order the reinstatement of strikers, even if they have left their employment, under Section 19 of Commonwealth Act No. 103.