GR 119467; (February, 2000) (Digest)
G.R. No. 119467 February 1, 2000
SAMAHAN NG MANGGAGAWA SA MOLDEX PRODUCTS, INC., ALEGRIA AQUINO AND 62 OTHERS, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER EDGARDO MADRIAGA, MOLDEX PRODUCTS, INC. AND MR. JACINTO UY, respondents.
FACTS
Petitioner Union and private respondent Moldex Products, Inc. reached a deadlock in CBA negotiations. The Union filed a notice of strike and conducted a strike vote. However, the report of the strike vote was never submitted to the National Conciliation and Mediation Board (NCMB). The Union proceeded to strike on May 5, 1993. Moldex filed a petition to declare the strike illegal, alleging that the strikers barricaded company gates and committed acts of violence, threats, and coercion.
Labor Arbiter Edgardo Madriaga declared the strike illegal and held that the union officers and members who committed prohibited acts had forfeited their employment status. The Union appealed to the NLRC, contending the company’s evidence was hearsay and unauthenticated. The NLRC vacated the Labor Arbiter’s decision and remanded the case for further proceedings, citing the need to receive crucial evidence, particularly the strike vote report. The Union’s motion for reconsideration was denied.
ISSUE
Whether the NLRC committed grave abuse of discretion in remanding the case to the Labor Arbiter for further reception of evidence.
RULING
Yes, the NLRC committed grave abuse of discretion. The Supreme Court held that a remand was unnecessary because the material facts for a legal resolution were already clear and complete. The critical fact was the Union’s admission that the strike vote report was never submitted to the NCMB. This failure alone rendered the strike illegal for non-compliance with the mandatory procedural requirement under Article 263 of the Labor Code.
The Court further ruled that the Labor Arbiter’s factual findings, which detailed the commission of illegal acts such as barricades, violence, and intimidation during the strike, were supported by substantial evidence. The petitioners’ objections regarding hearsay and the authentication of photographs were immaterial, as technical rules of evidence are not strictly applied in labor proceedings to serve substantial justice. Since the established facts conclusively showed an illegal strike, further proceedings would be a futile exercise. The Court reinstated the Labor Arbiter’s decision, declaring the strike illegal and upholding the forfeiture of employment status for the named union officers and members.