GR 143013; (December, 2000) (Digest)
G.R. Nos. 143013-14; December 18, 2000
TELEFUNKEN SEMICONDUCTORS EMPLOYEES UNION-FFW, DANILO G. MADARA and ROMEO L. MANAYAO, petitioners, vs. THE COURT OF APPEALS, HON. BIENVENIDO LAGUESMA, as Secretary of Labor and Employment, and TEMIC TELEFUNKEN MICROELECTRONICS, (PHILS.), INC., respondents.
FACTS
The labor dispute arose from a deadlock in collective bargaining negotiations between Telefunken Semiconductors Employees Union-FFW and Temic Telefunken Microelectronics (Phils.), Inc. The Union filed a Notice of Strike on August 28, 1995. Acting Secretary of Labor Jose S. Brillantes assumed jurisdiction over the dispute on September 8, 1995, issuing an Order that enjoined any strike or lockout. Despite personal service of this Assumption Order on Union representatives on September 8, 9, and 11, 1995, the Union proceeded to strike on September 14, 1995. The Acting Secretary subsequently issued a Return-to-Work Order on September 16, 1995. Many strikers, however, refused to comply and continued their picket, which later turned violent. The Company terminated the workers who defied the orders.
ISSUE
The primary issue was whether the Secretary of Labor committed grave abuse of discretion in declaring the strike illegal and in subsequently ordering the payment of backwages and financial assistance to the dismissed strikers.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the mandatory and binding nature of assumption and return-to-work orders issued by the Secretary of Labor under Article 263(g) of the Labor Code. Once the Secretary assumes jurisdiction, any strike undertaken thereafter is illegal per se. The Court found that the Union’s strike on September 14, 1995, was indisputably illegal because it was staged after the Secretary’s Assumption Order, which was validly served upon Union representatives. The strikers’ refusal to heed the subsequent Return-to-Work Order further solidified the illegality of their actions.
Consequently, the participating strikers lost their employment status. The Court held that the Secretary of Labor’s later directive for the Company to pay backwages and financial assistance constituted grave abuse of discretion. Such an award was inconsistent with the finding of an illegal strike, as it effectively rewarded unlawful conduct. The law is clear that workers who participate in an illegal strike may be validly dismissed. The Court emphasized that while the State affords protection to labor, this policy cannot be used to shield those who deliberately defy legal orders and engage in prohibited activities. The Secretary’s orders for monetary awards were therefore correctly nullified by the Court of Appeals for being issued with grave abuse of discretion amounting to lack or excess of jurisdiction.