G.R. No. 153799, September 17, 2012
Solidbank Union, et al. vs. Metropolitan Bank and Trust Company

FACTS

This case consolidates three petitions arising from a labor dispute. Solidbank Corporation was acquired by Metropolitan Bank and Trust Company (Metrobank). Following the acquisition, Solidbank Union filed a notice of strike, alleging unfair labor practices including illegal dismissal, union busting, and violations of the collective bargaining agreement. The union declared a strike, which Metrobank contended was illegal. The National Labor Relations Commission (NLRC) ruled the strike illegal, finding that the union committed prohibited acts such as preventing non-striking employees from working. Consequently, the NLRC declared the loss of employment status of the union officers who participated in the strike. The Court of Appeals affirmed this decision.
The union and the dismissed officers filed a petition arguing the strike was legal. In a separate petition, Metrobank challenged the appellate court’s decision to reinstate certain individual employees who were not union officers, contending they also participated in illegal acts during the strike. Solidbank Corporation and its officers also filed a petition, essentially aligning with Metrobank’s position against the reinstatement of the individual members.

ISSUE

The core issue is whether the strike declared by Solidbank Union was illegal, and consequently, whether the dismissal of the participating union officers and members was valid.

RULING

The Supreme Court affirmed the findings of the NLRC and the Court of Appeals that the strike was illegal. The legal logic rests on the union’s commission of prohibited acts during the strike, which rendered the strike illegal under Article 264 of the Labor Code. The Court upheld the factual findings that the strikers blocked the entry of non-striking employees and company vehicles, effectively preventing the free ingress to and egress from the company premises. Such acts constitute serious misconduct under the law.
Consequently, the union officers, having knowingly participated in the illegal strike, were deemed to have lost their employment status. The Court applied the doctrine that participation in an illegal strike is a valid ground for dismissal. However, for the individual union members who were not officers, the Court sustained the appellate court’s modification. Mere participation in an illegal strike does not automatically result in loss of employment; it must be shown that the member committed illegal acts during the strike. Since Metrobank failed to present sufficient evidence that each of these individual members committed specific illegal acts, their dismissals were not justified. The Court emphasized the principle that while the legality of a strike is a legal conclusion, the determination of prohibited acts is factual, and the findings of the NLRC, when supported by evidence, are accorded respect.