Bohol Land Transportation Company v. Bohol Land Transportation Employees Labor Union
REITERATIONFacts
The Antecedents: An industrial dispute existed between Bohol Land Transportation Co. (petitioner) and its employees, members of the BLT Employees Labor Union (respondent). The dispute involved several demands, but all were amicably settled except for the reinstatement of ten dismissed employees. The Secretary of Labor certified the dispute to the Court of Industrial Relations (CIR). Procedural History: The CIR commissioned a special agent to receive evidence regarding the dismissed employees. On April 20, 1940, the CIR ordered the reinstatement of three employees: David Fernandez, Joaquin Matig-a, and Facundo Capuno, approving the dismissal of others. Petitioner agreed to Capuno's reinstatement but moved for reconsideration regarding Fernandez and Matig-a. The CIR denied this motion on July 31, 1940. The Petition: Petitioner filed a petition for a writ of certiorari, assailing the CIR's decision and resolution, particularly the order for the reinstatement of Fernandez and Matig-a. Petitioner assigned errors concerning the CIR's jurisdiction and its findings of fact regarding the reasons for dismissal.
Issue(s)
Whether the Court of Industrial Relations erred in taking cognizance of the dismissal of David Fernandez and Joaquin Matig-a. Whether the Court of Industrial Relations erred in finding that David Fernandez was dismissed due to his union activities. Whether the Court of Industrial Relations erred in finding that Joaquin Matig-a was dismissed due to his union activities.
Ruling
The petition for a writ of certiorari is denied, and the decision of the Court of Industrial Relations is affirmed.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations: The Court held that the CIR has jurisdiction to pass upon and determine the legality or propriety of an employee's dismissal or lay-off if this question arises from an industrial dispute certified to it, even if the dismissal occurred prior to the certification. The Court reasoned that the dismissal of David Fernandez and Joaquin Matig-a was intrinsically linked to the certified industrial dispute, constituting an unfair labor practice and a controversy between employer and employees, which the CIR is empowered to adjudicate under Commonwealth Act No. 103. The circumstance of the dismissal preceding the certification does not divest the CIR of its authority to resolve issues arising from the certified dispute. On the dismissal of David Fernandez: The Court affirmed the CIR's finding that David Fernandez was dismissed due to his union activities. The CIR found that Fernandez was dismissed after being granted verbal permission by the company president to be absent, and his subsequent failure to report was due to this approved leave. The Court noted that Fernandez was the president of the strikers' control board and played a significant role in the union movement. Therefore, the CIR concluded that the dismissal was motivated by retaliation and a desire to remove a valuable union element, rather than abandonment of work or insubordination. On the dismissal of Joaquin Matig-a: The Court upheld the CIR's finding that Joaquin Matig-a was dismissed due to his union activities, rejecting the petitioner's claim of position suppression for economic reasons. The CIR found that Matig-a was a board member of the union and an organizer of the strike, maintaining peace and order among the strikers and being a feared figure among them. The Court also found that the 'checker' position Matig-a held was necessary and that he was not informed of any suppression of his position when dismissed. Instead, the company president explicitly stated he was dismissed because the president willed it, indicating a retaliatory motive rather than a legitimate economic reason.
Main Doctrine
The Court of Industrial Relations has jurisdiction to pass upon and determine the legality or propriety of an employee's dismissal or lay-off if this question arises from an industrial dispute certified to it, even if the dismissal occurred prior to the certification. Findings of fact by the Court of Industrial Relations will not be disturbed absent a showing of grave abuse of discretion.