GR 117169; (March, 1997) (Digest)
G.R. No. 117169 March 12, 1997
PHILTREAD WORKERS UNION (PTWU), ET AL., petitioners, vs. SECRETARY NIEVES R. CONFESOR, NATIONAL LABOR RELATIONS COMMISSION, ET AL., respondents.
FACTS
Petitioner Philtread Tire Workers Union filed a notice of strike on grounds of unfair labor practice, while respondent Philtread Tire and Rubber Corporation filed a notice of lockout. Conciliation failed, leading to a company-wide lockout from June to August 1994 and the dismissal of about eighty union members. The National Labor Relations Commission subsequently declared union slowdowns illegal. On August 31, 1994, the company requested the Secretary of Labor to assume jurisdiction over the dispute. Secretary Nieves Confesor issued an order on September 8, 1994, certifying the entire labor dispute to the NLRC for compulsory arbitration, enjoining any strike or lockout, and directing striking workers to return to work. Petitioners filed a motion for reconsideration, which was denied.
ISSUE
The primary issues are: (1) whether Article 263(g) of the Labor Code, granting the Secretary of Labor the power to assume jurisdiction or certify disputes for compulsory arbitration, is unconstitutional for allegedly violating the constitutional right to strike; and (2) whether the Secretary of Labor committed grave abuse of discretion in issuing the certification order in this specific case.
RULING
The Supreme Court dismissed the petition, affirming the Secretary of Labor’s order. On the constitutional challenge, the Court ruled that Article 263(g) of the Labor Code remains valid. This provision, enacted pursuant to the state’s police power to promote order and general welfare, had not been repealed by the 1987 Constitution . Its continued validity was recognized by Congress when it was amended by R.A. 6715. The constitutional right to strike is not absolute and may be restricted by law in the interest of national welfare.
Regarding the allegation of grave abuse of discretion, the Court found none. The Secretary of Labor correctly determined that the dispute was imbued with national interest. Philtread employed about 700 workers and supplied approximately 22% of domestic tire products. A prolonged work disruption threatened the livelihood of these workers, risked company closure, and could aggravate unemployment, thereby adversely affecting economic recovery and discouraging investment. The Secretary’s intervention was a necessary exercise of her statutory power to prevent exacerbation of the situation. Grave abuse of discretion implies capricious or whimsical judgment equivalent to lack of jurisdiction, which was not present given the well-founded basis for the order.