Philippine Refining Workers' Union v. Philippine Refining
REITERATIONFacts
The Antecedents: On September 26, 1946, the Court of Industrial Relations (CIR) attempted to settle Case No. 32-V between the Philippine Refining Company, Inc. (PRCI) and the Philippine Refining Company Workers' Union (CLO). The CIR issued an order directing striking laborers to return to work on September 27, 1946, and enjoining them from staging strikes or walkouts without court authority. The company was also enjoined from laying off or dismissing employees without prior court notification and authority. Procedural History: On May 2, 1947, PRCI reported to the CIR that the union had declared a strike on April 30, 1947. The CIR, in an order dated July 24, 1947, declared the strike contemptuous and illegal for violating a previous court order. The company was authorized to hire striking laborers and new employees at its discretion. Atty. Juan Maralit was designated to handle contempt proceedings. The union's answer and counter-petition for contempt were dismissed. Motions for reconsideration filed by the union were denied by resolutions dated August 16 and September 15, 1947. The Petition: The Philippine Refining Company Workers' Union (CLO) filed the instant petition seeking to vacate and reverse the CIR's orders and resolutions, contending that the CIR acted without or in excess of jurisdiction, that the orders infringed upon constitutional rights and prohibited involuntary servitude, and that the orders were issued in violation of due process.
Issue(s)
Whether the CIR's order dated September 26, 1946, enjoining the workers from staging a strike pending final determination of the case, was issued without or in excess of its jurisdiction and powers. Whether the said order dated September 26, 1946, is null, void, and invalid for infringing upon the constitutional rights and liberties of the workers and for being repugnant to the constitutional inhibition against involuntary servitude. Whether the CIR's order dated July 24, 1947, and the subsequent resolutions denying motions for reconsideration, are invalid and contrary to law for violation of the due process clause, alleging lack of legal and fair hearing.
Ruling
The Supreme Court affirmed the orders and resolutions of the Court of Industrial Relations, with costs against the petitioners. The Court held that the CIR acted within its jurisdiction and powers in issuing the questioned orders, that these orders did not violate constitutional rights or the prohibition against involuntary servitude, and that the proceedings complied with due process.
Ratio Decidendi
On the jurisdiction and powers of the CIR to enjoin strikes: The Court reiterated its ruling in Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas vs. Gotamco Saw Mill that Section 19 of Commonwealth Act No. 103 grants the CIR the power to order striking workers to return to work, particularly when public interest requires it or when the dispute cannot be promptly decided or settled. The order of September 26, 1946, was issued after a series of conferences with both parties, satisfying the requirement of a hearing. The CIR explicitly stated in its order that it might not be able to decide the case promptly due to the issues involved, thus justifying the injunction under the said provision. The power to enjoin strikes and order return to work is considered a vital aspect of capital-labor legislation aimed at preventing undue stoppage of industry. On the alleged infringement of constitutional rights and involuntary servitude: The Court affirmed that Section 19 of Commonwealth Act No. 103 does not offend against the constitutional inhibition against involuntary servitude. Employees entering into employment contracts after the law took effect voluntarily accept, as an implied condition, that they shall not strike or walk out when enjoined by the court after hearing and when public interest so requires, or when the dispute cannot be promptly decided or settled. The voluntariness of entering into such a contract, with the employee having a free choice, negates the possibility of involuntary servitude. The CIR's orders were issued to facilitate the settlement of a labor dispute, not to compel work against an employee's will. On the alleged violation of due process: The Court stated that it is not authorized to review the findings of fact made by the Court of Industrial Relations, as per Section 15 of Commonwealth Act No. 103, as amended, and relevant Rules of Court. The CIR's order of September 26, 1946, was issued after a series of conferences with both parties, which constituted a hearing. The subsequent order of July 24, 1947, was a consequence of the union's violation of the prior court order. Therefore, the proceedings leading to the orders and resolutions did not violate the due process clause, as the parties were given an opportunity to be heard, and the CIR acted within its statutory powers.
Main Doctrine
The Court of Industrial Relations has the power to enjoin strikes and order striking laborers to return to work when public interest so requires or when the dispute cannot be promptly decided or settled, as such orders are not violative of the constitutional prohibition against involuntary servitude, given that employees voluntarily accept such conditions upon entering into employment contracts under Commonwealth Act No. 103.