Manila Trading & Supply Co. v. Philippine Labor Union
REITERATIONFacts
The Antecedents: On December 29, 1939, during the pendency of an industrial dispute between Manila Trading & Supply Company (petitioner) and Philippine Labor Union (respondent), Felix Alcantara, an employee and union member, was dismissed by the company's superintendent for alleged disorderly conduct. The conduct in question involved laborers blowing horns of cars in celebration of the New Year, a practice tolerated by the company for two years prior. While it was unclear if Alcantara was among those who blew the horns, the investigator found the practice to be tolerated. Procedural History: The Court of Industrial Relations, based on the investigator's report, found Alcantara's dismissal to be without just cause and ordered his reinstatement with back wages. A motion for reconsideration was denied. The Petition: The company filed a petition for certiorari, raising two main issues: (1) whether a decision based on a commissioner's report without a prior hearing violates the right to a fair and open hearing, and (2) whether an employer can discharge employees at pleasure under Commonwealth Act No. 103, provided it's not due to union affiliation.
Issue(s)
Whether a decision by the Court of Industrial Relations (CIR) based on a commissioner's report without a prior hearing thereon constitutes a deprivation of the right to a fair and open hearing. Whether an employer, under Commonwealth Act (CA) No. 103, may discharge employees at will provided the discharge is not due to union affiliation. Whether the Court of Industrial Relations (CIR) loses jurisdiction over an incidental dispute after the main labor dispute has been finally decided.
Ruling
The petition for certiorari is denied, and the order of the Court of Industrial Relations is affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court held that there was no deprivation of due process. Citing its prior ruling in Manila Trading & Supply Company v. Philippine Labor Union (G.R. No. 47486), the Court reiterated that when the Court of Industrial Relations (CIR) refers a case to a commissioner for investigation and report, the requirement of due process is satisfied if the parties were represented by counsel and given an opportunity to be heard during the investigation. The failure of the CIR to set the report for a separate hearing before rendering a decision does not invalidate the 'fair and open hearing' requirement. The evidence gathered by the commissioner, along with other records, provides a sufficient basis for a valid adjudication. On Issue 2: The Court rejected the petitioner's claim of an absolute right to discharge employees. It ruled that while an employer cannot be compelled to retain an employee if a 'justifiable cause' for discharge exists, the Court of Industrial Relations (CIR) has the power under Section 19 of Commonwealth Act (CA) No. 103 to determine whether such cause actually exists. This power is incidental to the court's authority over a pending industrial dispute. The Court emphasized that the policy of 'laissez faire' has yielded to government intervention in contractual relations affected with public interest, as previously established in Ang Tibay v. Court of Industrial Relations. On Issue 3: The Court ruled that the Court of Industrial Relations (CIR) retains jurisdiction over incidental disputes even after the main labor dispute is adjudicated. The jurisdiction exercised under Section 19 of Commonwealth Act (CA) No. 103 is an extension of the jurisdiction acquired under Section 4 of the same law. Therefore, since the incidental dispute regarding Alcantara's dismissal was submitted during the pendency of the main dispute, the court's authority to resolve it continues until a final decision is reached on that specific incident, regardless of the status of the main case.
Main Doctrine
The Court of Industrial Relations has the authority to determine whether a cause for discharge exists, even if the discharge is not due to union affiliation or activities, and its findings on the appreciation of evidence, if not whimsical, will not be disturbed.