G.R. No. L-8116 August 25, 1956
SCOTY’S DEPARTMENT STORE, ET AL., petitioner, vs. NENA MICALLER, respondent.

FACTS

Nena Micaller was a salesgirl at Scoty’s Department Store, owned and operated by Yu Ki Lam, Richard Yang, Yu Si Kiao, and Helen Yang. She filed charges of unfair labor practice against her employers under the Industrial Peace Act, alleging she was dismissed due to her membership and activities in the National Labor Union. The employers countered that her dismissal was due to misconduct and disrespect, citing pending criminal charges filed against her. The Court of Industrial Relations found that prior to her dismissal, Micaller was a model employee with good earnings and bonuses. In October 1953, she helped organize a union among the store’s employees. The management subsequently engaged in a series of acts: questioning Micaller about union membership in the manager’s office; visiting her home to question her; bringing her to their lawyer’s office where she was made to sign a union withdrawal paper; and questioning each employee about union membership. After the union filed a strike notice, the management hired temporary employees affiliated with a different union. Micaller was dismissed on November 30, 1953, for allegedly insulting the owner and talking to other employees during business hours. The industrial court found the petitioners guilty of unfair labor practice, imposed a P100 fine, and ordered Micaller’s reinstatement with back pay.

ISSUE

1. Whether the Court of Industrial Relations erred in finding that Nena Micaller was dismissed due to her union membership and activities, constituting unfair labor practice.
2. Whether the Court of Industrial Relations had jurisdiction to impose the P100 fine prescribed under Section 25 of Republic Act No. 875 (the Industrial Peace Act).

RULING

1. The Supreme Court declined to review the factual findings of the Court of Industrial Relations that the petitioners committed unfair labor practice. The industrial court’s determination that the employers subjected Micaller and other employees to questioning regarding union membership and activities, acts deemed unfair labor practice under Section 4(a)(4) of Republic Act No. 875 , was binding. The Court cited analogous American jurisprudence (NLRB vs. Harris-Woodson Co.) which condemns such questioning and anti-union expressions as violations, and supports the finding that the stated grounds for dismissal were a pretext for union-related discrimination.
2. The Supreme Court ruled that the Court of Industrial Relations does not have jurisdiction to impose the criminal penalties (fine or imprisonment) provided in Section 25 of Republic Act No. 875 . The procedure of the industrial court, which is not bound by strict rules of evidence and may ascertain facts without regard to technicalities, negates the constitutional guarantees of due process and the rights of an accused in a criminal prosecution, such as the right to be confronted by witnesses and the requirement of proof beyond reasonable doubt. A comparative analysis of the legislative intent behind the creation of quasi-judicial bodies like the Court of Agrarian Relations indicated a design to exclude criminal jurisdiction from such tribunals. Therefore, the power to impose penalties under Section 25 is lodged in the ordinary courts. Consequently, the portion of the industrial court’s order imposing a P100 fine was nullified. The order for reinstatement with back pay was affirmed.