GR 148021; (December, 2006) (Digest)
G.R. No. 148021 ; December 6, 2006
SIME DARBY EMPLOYEES ASSOCIATION, ET AL., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, ET AL., and SIME DARBY PILIPINAS, INC., ET AL., respondents.
FACTS
Petitioners, members of the Sime Darby Employees Association, submitted a proposal in October 1995 to amend the remaining two years of their Collective Bargaining Agreement with Sime Darby Pilipinas, Inc. Negotiations reached an impasse, leading the company to declare a deadlock and file a Notice of Lockout. The union, in turn, conducted a strike vote. On August 6, 1995, the company implemented a lockout against its hourly tire factory employees, citing alleged sabotage and work slowdown. The union filed a complaint for illegal lockout.
Subsequently, in October 1995, the company’s stockholders approved the sale of its tire manufacturing assets and business. The company informed employees of this sale and eventually terminated their employment, offering separation benefits. Many employees accepted the benefits and executed quitclaims. The union then amended its complaint to include illegal dismissal.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s dismissal of the complaints for illegal lockout and illegal dismissal.
RULING
The Supreme Court denied the petition and affirmed the assailed rulings. On procedural grounds, the petitioners failed to demonstrate that the NLRC committed grave abuse of discretion. The Labor Arbiter did not err in deciding the case based on position papers without a formal hearing, as the issues involved were primarily legal and the facts were sufficiently established by the submitted pleadings and evidence. This is in accordance with the NLRC’s rules allowing summary proceedings.
On substantive grounds, the Court found the lockout legal. The company had a valid ground to declare a deadlock after good-faith negotiations failed, and the alleged sabotage and work slowdown constituted a valid ground for a defensive lockout under the Labor Code. Regarding the dismissal, the Court upheld that it was due to a bona fide cessation of the company’s tire business operation, a recognized authorized cause for termination under Article 283 of the Labor Code. The employees’ voluntary acceptance of separation benefits and execution of quitclaims, absent proof of vitiated consent, constituted a valid waiver of their claims, barring them from pursuing the illegal dismissal case.