G.R. No. L-33725 August 31, 1978
NATIONAL LABOR UNION, petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS and VICTORY LINER, INC., respondents.

FACTS

The petitioner union filed an unfair labor practice (ULP) charge against Victory Liner, Inc. on behalf of its member, Pacifico Navarro, a bus driver. The complaint alleged that Navarro was refused trip assignments starting March 23, 1959, and was eventually dismissed on September 8, 1959, due to his union membership and activities. The union claimed that the company’s general manager confronted Navarro about his association with union officers and told him to seek work from the union instead.
Victory Liner defended the dismissal by citing a serious accident on March 24, 1959, caused by Navarro’s alleged gross negligence and reckless imprudence, which injured passengers and damaged company property. The company asserted that after investigation, and considering Navarro’s prior record of misdemeanors, it terminated his employment on September 1, 1959, for the safety of the public and the good of the service, denying any anti-union motive.

ISSUE

Whether the Court of Industrial Relations (CIR) en banc erred in absolving Victory Liner of the unfair labor practice charge and in not ordering the reinstatement of Pacifico Navarro with back wages.

RULING

The Supreme Court affirmed the CIR en banc resolution, finding no merit in the petition. The legal logic rests on two key principles. First, the Court emphasized that factual findings of the CIR, when supported by substantial evidence, are conclusive. The petitioner failed to demonstrate that the CIR’s factual conclusion—that the dismissal was due to Navarro’s negligence in the accident and not his union activities—was unsupported. In ULP cases, the quantum of proof required is substantial evidence, not preponderance of evidence. The CIR’s finding that the company’s justification was credible and not a mere pretext for union-busting was thus binding.
Second, the Court clarified the limited scope of the remedy. The complaint was exclusively for ULP. Once the CIR correctly found no ULP, it lost jurisdiction to order reinstatement and back wages under that specific charge. The Court held that a dismissal without just cause, if not proven to be an ULP, constitutes a mere breach of contractual obligation redressable through an ordinary action for damages, not through the ULP machinery of the CIR. Therefore, the CIR en banc did not err in absolving the company and in refraining from granting reinstatement, as that relief was contingent upon a finding of ULP, which was not established.