G.R. No. L-19879 December 17, 1966
CINEMA, STAGE & RADIO ENTERTAINMENT FREE WORKERS’ (FFW), MARCIANO DE CASTRO, BRUNO AZORES, and RUFINA FERNANDEZ, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, ANGEL GARCHITORENA and LUIS GARCHITORENA, respondents.

FACTS

Petitioners, a union and its members Marciano de Castro, Bruno Azores, and Rufina Fernandez, filed a complaint for unfair labor practice against respondents Angel and Luis Garchitorena, owners/operators of theaters. The complaint alleged that after learning of the union’s organization, respondents called a meeting on November 16, 1954, where Angel Garchitorena spoke ill of unionism. It was further alleged that petitioners were offered a consideration to dissolve their union and form a management-dominated one, and upon refusal, they were dismissed on November 21, 1954. Respondents moved to dismiss, arguing petitioners were supervisory employees and were dismissed for just cause. The Court of Industrial Relations (CIR), adopting the Examiner’s report, rendered a decision on March 12, 1962, exonerating respondents from unfair labor practice charges, finding that the dismissals were for just causes: habitual drunkenness (De Castro); giving free admissions, negligence, and inefficiency (Azores); and dishonesty, giving free admissions, and gossiping on duty (Fernandez). The CIR, however, directed payment of separation pay. Petitioners’ motion for reconsideration was denied by the CIR en banc on April 10, 1962, prompting this petition for review.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion or serious errors of law in finding that petitioners were dismissed for just causes and not due to their union activities.

RULING

The Supreme Court affirmed the decision and resolution of the Court of Industrial Relations. The Court held that the factual findings of the CIR, which concluded that the dismissals were for just causes and not due to union activities, are binding. The Court addressed petitioners’ specific arguments: (1) Their transfers were routine policy to avoid connivance; (2) Respondent Angel Garchitorena’s statements at the meeting were not an angry scolding but a commentary on union purpose, as corroborated by witnesses; (3) The simultaneous dismissal, despite different causes, was because respondent Angel Garchitorena, who was in Spain, had instructed that no dismissals occur until his return; (4) There was no evidence petitioners were not held responsible for their bad actuations; and (5) The money received was found to be a Christmas bonus, not separation pay. The Court found the cited labor relations doctrine on dual motivation inapplicable, as the CIR found the sole motivation was just cause, not anti-union sentiment. The petition was denied, with costs against petitioners.