GR 26169; (June, 1970) (Digest)

G.R. No. L-26169 and L-26178 June 30, 1970
NATIONAL POWER CORPORATION, petitioner, vs. NATIONAL POWER CORPORATION EMPLOYEES AND WORKERS ASSOCIATION and COURT OF INDUSTRIAL RELATIONS, respondents. (G.R. No. L-26169) / NATIONAL POWER CORPORATION EMPLOYEES AND WORKERS ASSOCIATION, petitioner, vs. NATIONAL POWER CORPORATION and COURT OF INDUSTRIAL RELATIONS, respondents. (G.R. No. L-26178)

FACTS

An industrial dispute arose between the National Power Corporation (NPC) and the National Power Corporation Employees and Workers Association (the Union) following a strike declared by the Union on January 11, 1966. The dispute centered on the Union’s demand for the reopening of negotiations for a 21% across-the-board salary increase, even before the expiration of the existing collective bargaining agreement, alleging that certain promotions by the NPC entitled them to such reopening. The President of the Philippines certified the dispute to the Court of Industrial Relations (CIR) for compulsory arbitration under Section 10 of Republic Act 875 (The Industrial Peace Act), noting that the NPC’s operations were indispensable to the national interest and a stoppage would cause huge economic losses, untold inconveniences, and grave dangers to safety and human life. After hearings, the Presiding Judge of the CIR rendered a partial decision on January 18, 1966, affirmed by the CIR en banc on February 11, 1966, granting the Union’s demand for a 21% salary increase based on basic pay, to be staggered over three years (11% effective January 1, 1965, 5% on January 1, 1967, and 5% on January 1, 1968), and excluding eleven supervisors who had already received increases beyond the collective bargaining agreement. The NPC and the Union both appealed this partial decision to the Supreme Court. The NPC specifically assigned as error that the CIR disposed of the economic demand without first resolving the issue of the validity or legality of the January 11, 1966 strike, a question the NPC had raised before the CIR.

ISSUE

Whether the Court of Industrial Relations erred in deciding the Union’s economic demand for a 21% across-the-board salary increase without first resolving the issue of the validity or legality of the strike of January 11, 1966.

RULING

Yes. The Supreme Court ruled that the Court of Industrial Relations erred in rendering a partial decision granting the wage increase without first resolving the crucial issue of the strike’s legality, which had been squarely raised by the NPC management. The Court, citing its precedent in Philippine Can Co. v. Court of Industrial Relations, held that the CIR should first determine the validity of a strike when such an issue is properly raised before deciding on the economic demands. While the doctrine in the Philippic Can Co. case had been relaxed in other decisions (such as FEATI University v. Bautista, Maritime Co. of the Phil. v. Paredes, and Philippine Long Distance Telephone Co. v. Free Telephone Workers Union) where the legality of a strike need not be inquired into, the situation in this case required a determination of the strike’s validity as crucial to the proper disposition of the matter. The Supreme Court found no adverse effect in requiring the CIR to pass upon the strike’s legality first, noting that the CIR had the power to order the strikers back to work in the interim to avoid the dire consequences cited in the presidential certification. Consequently, the Supreme Court remanded both cases (G.R. No. L-26169 and G.R. No. L-26178) to the Court of Industrial Relations for appropriate proceedings not inconsistent with this opinion.