G.R. No. L-15265; April 27, 1962
BAGUIO GOLD MINING COMPANY, petitioner, vs. BENJAMIN TABISOLA, JOSE MONTECLARO, and THE COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

Benjamin Tabisola and Jose Monteclaro filed an unfair labor practice complaint against Baguio Gold Mining Company, alleging they were dismissed on February 18, 1957, for refusing to cease campaigning for union membership after a threat from the company’s general superintendent. The Court of Industrial Relations (CIR) found the evidence insufficient to substantiate the claim that the dismissals were due to union activities. Consequently, it dismissed the complaint for unfair labor practice.
However, the CIR proceeded to order the company to reinstate both employees. It awarded Tabisola full back wages from the date of his dismissal until actual reinstatement, finding he was dismissed “for no cause, just or otherwise.” For Monteclaro, the CIR found his dismissal was due to unruly behavior in the office, which it deemed an insufficiently grave violation to warrant dismissal, thus also ordering his reinstatement but without back wages.

ISSUE

Does the Court of Industrial Relations have the authority to order reinstatement and award back wages in an unfair labor practice case where the employer is found not guilty of the charged unfair labor practice?

RULING

No. The Supreme Court ruled that the CIR lacks such authority. The legal logic is anchored on the distinct nature of proceedings under Republic Act No. 875 (the Industrial Peace Act). The power of the CIR to order reinstatement with or without back pay is expressly granted by Section 5(c) of RA 875 only when the court finds that the person charged has engaged in an unfair labor practice. Conversely, when the charge is not substantiated and the complaint is to be dismissed, this remedial authority is implicitly withheld; the court’s duty is simply to dismiss the complaint.
The Court rejected the argument that the CIR’s broad powers under Commonwealth Act No. 103 (creating the CIR) could be invoked to justify the order. It clarified that the reinstatement power under CA 103 is confined to the court’s arbitral and conciliatory functions in industrial disputes likely to cause a strike or lockout, which are separate from unfair labor practice cases. Unfair labor practice proceedings are prosecuted akin to public offenses, and the CIR is specifically inhibited from exercising arbitration and conciliation powers in such cases. The remedy for an employee whose unfair labor practice charge fails but who believes his dismissal was unjustified lies in an ordinary civil action for breach of contract, not within the CIR’s continuing jurisdiction in the dismissed unfair labor practice case. The appealed decision was modified by eliminating the order for reinstatement and back wages.