G.R. No. L-20662 March 27, 1971
PHILIPPINE MARINE OFFICERS’ GUILD, petitioner, vs. COMPAÑIA MARITIMA, PHILIPPINE STEAM NAVIGATION CO., MADRIGAL SHIPPING CO., CIR ASSOCIATE JUDGES ARSENIO MARTINEZ, BALTAZAR VILLANUEVA and AMANDO BUGAYONG, respondents.

FACTS

The petitioner, Philippine Marine Officers’ Guild (PMOG), filed a motion for reconsideration of a prior Supreme Court decision that affirmed the Court of Industrial Relations’ (CIR) denial of its members’ claim for back wages against respondents Philippine Steam Navigation Company (PHILSTEAM) and Madrigal Shipping Company (MADRIGAL). The dispute originated from a strike. The CIR had issued a return-to-work order, which the strikers unconditionally offered to obey. However, the Supreme Court subsequently issued a permanent injunction against the enforcement of that CIR order. The strikers were eventually ordered reinstated but were denied back wages by the CIR, a denial affirmed by the Supreme Court.
PMOG’s motion for reconsideration argued that its members, having made an unconditional offer to return to work in compliance with the CIR order, acquired the status of illegally dismissed employees when not reinstated and were thus entitled to back wages. It contended that all legal conditions for such an award were met: the strike’s legality was final, the offer to return was unconditional, and reinstatement was refused. It further argued that the Supreme Court’s injunctive order should not bar the back wage claim and that the shipping companies should bear the financial consequences of their refusal to reinstate.

ISSUE

Whether the striking employees of PHILSTEAM and MADRIGAL are entitled to payment of back wages for the period following their unconditional offer to return to work.

RULING

The Supreme Court denied the motion for reconsideration, upholding the denial of back wages. The legal logic is clear and multi-faceted. First, the Court found the premise of PMOG’s claim—that the CIR’s return-to-work order was valid and lawful—to be fundamentally flawed. The Court’s own act of issuing a permanent injunction against that order’s enforcement conclusively established its invalidity for the purposes of this claim. Since the strikers’ offer to return was predicated solely on complying with this invalidated order, they could not legitimately claim a right to reinstatement and back wages based on that offer.
Second, the Court deferred to the factual finding of the CIR, supported by substantial evidence, that “none of the companies had discriminately rejected their application for reemployment.” This finding directly negated the essential element of a wrongful refusal to reinstate necessary for a back wage award. Third, the Court noted the absence of any renewed offer to return to work after the Supreme Court’s injunction nullified the basis for the initial offer. The circumstances surrounding the issuance of the permanent injunction and the subsequent events led the CIR to conclude the companies were not at fault for the failure to rehire promptly. Therefore, imposing back wages on PHILSTEAM and MADRIGAL would be unfair and unjust under the specific factual complex of this case. The claim for back wages was correctly denied.