GR L 56856; (October, 1984) (Digest)
G.R. No. L-56856 October 23, 1984
HENRY BACUS, ET AL., petitioners, vs. HON. BLAS F. OPLE, Minister of Labor and Employment and FINDLAY MILLAR TIMBER COMPANY, respondents.
FACTS
Petitioners, employees of Findlay Millar Timber Company, participated in a mass walkout on February 19, 1979, protesting unpaid wages and alleged non-compliance with labor standards. The Minister of Labor assumed jurisdiction and issued a return-to-work order. The company subsequently filed applications for clearance to terminate the petitioners, alleging they committed serious illegal acts during the strike, including coercion, intimidation, and stoning, which caused significant financial losses. The Deputy Minister of Labor, in a decision dated October 18, 1979, declared the strike illegal and granted the clearance to dismiss the petitioners. Their motion for reconsideration was denied by Minister Blas Ople on March 10, 1981.
ISSUE
Whether the Deputy Minister of Labor committed grave abuse of discretion in declaring the strike illegal and authorizing the dismissal of the petitioners without conducting a hearing on the specific charges of serious misconduct against them.
RULING
Yes. The Supreme Court granted the petition, annulled the decision, and ordered a new hearing. The Court ruled that while the Minister of Labor has the authority to assume jurisdiction and decide labor disputes, the power to declare a strike illegal is distinct from the power to dismiss individual workers for specific acts of misconduct. The Deputy Minister’s finding that the strike was illegal was based on its violation of the return-to-work order. However, the dismissal of the petitioners was predicated on the separate and graver charge of committing serious acts of violence.
The legal logic is clear: due process mandates that an employee sought to be dismissed for a cause attributable to him must be given the opportunity to be heard and to present evidence in his defense. The Deputy Minister’s consolidated decision, which declared the strike illegal and authorized dismissal based on alleged violence, was rendered without conducting a formal hearing where the petitioners could confront the evidence and witnesses against them. The charges of stoning and intimidation are factual allegations requiring evidentiary substantiation. By ordering dismissal based on these unproven charges without a trial-type hearing, the Deputy Minister deprived the petitioners of their fundamental right to due process, thereby acting with grave abuse of discretion. The case was remanded for a proper hearing on the specific charges of violence.