G.R. Nos. 158190-91 and 158276, 158283; October 31, 2006
Nissan Motors Philippines, Inc. vs. Secretary of Labor and Employment, et al. and Bagong Nagkakaisang Lakas sa Nissan Motors Philippines, Inc. (BANAL-NMPI-OLALIA-KMU) vs. Court of Appeals, et al.

FACTS

A collective bargaining deadlock between Nissan Motors Philippines, Inc. and the union BANAL-NMPI-OLALIA-KMU led to a labor dispute involving multiple notices of strike and employee dismissals. The Secretary of Labor assumed jurisdiction over the dispute, issuing an order that enjoined any strike or lockout. Despite this, union officers and members engaged in a work slowdown, which was deemed an illegal strike in defiance of the assumption order. Consequently, Nissan dismissed the involved employees.
The Secretary of Labor, in a decision dated December 5, 2001, affirmed the suspension of 140 employees related to the first notice of strike, sustained the dismissal of the union officers, but recalled the dismissal of the union members. The union members were instead ordered reinstated without back wages and were deemed to have served a one-month suspension. A subsequent resolution dated January 22, 2002 modified this by reinstating three individuals erroneously identified as officers. The Court of Appeals affirmed this disposition, and the Supreme Court, in a Decision dated June 21, 2006, ultimately sustained the appellate court.

ISSUE

Whether the Supreme Court’s Decision requires clarification regarding the specific identities of the union members ordered reinstated pursuant to the affirmed Secretary of Labor’s decision.

RULING

The Supreme Court resolved that no clarification was necessary. The Court held that while the dispositive portion of the Secretary of Labor’s decision did not enumerate names, the body of the decision explicitly addressed the issue of dismissal and specifically listed 44 names under the heading “Union officers and members dismissed.” Furthermore, the text of the decision clearly differentiated the treatment between union officers and members. It stated that the officers were dismissed for leading the illegal strike in defiance of the assumption order, but the members, who were merely following orders and with no evidence of participating in illegal activities, should be reinstated without back wages, albeit with a one-month suspension deemed served. This explanatory text within the decision provided sufficient basis to identify the affected individuals, rendering the motion for clarification without merit. The Court thus denied the union’s motion.