G.R. No. L-37174. May 31, 1978.
LITTON MILLS WORKERS UNION-CCLU, petitioner, vs. LITTON MILLS, INC., LITTON KNITTING MILLS, INC. and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

In May 1963, petitioner Litton Mills Workers Union filed an unfair labor practice complaint (Case No. 3718-ULP) against the respondent companies. The complaint alleged that the companies interfered with union activities, dismissed union president Anita Lorenzo, and, following a strike declared on April 15, 1963, dismissed 45 specifically named employees as a retaliatory act. It also stated that the union’s members, numbering “more or less 500,” picketed and that the union offered to return to work in October 1963, but the companies did not respond. The companies filed a related case (No. 3724) against the union for an illegal strike. The two cases were consolidated.
After over six years of trial, settlement talks began in early 1970. The companies offered separation pay to the 45 named complainants. The union then sought to include an additional 423 members for reinstatement. When the companies objected, the union filed a motion in January 1970 to amend its 1963 complaint to list these 423 names. The trial judge denied this motion. The union then persuaded the court’s Acting Assistant Chief Prosecutor to file an amended complaint in October 1972, formally seeking reinstatement for the 423 additional workers. The Court of Industrial Relations en banc disallowed this amended complaint in June 1973, prompting this petition.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in disallowing the amended complaint that sought to include 423 additional workers for reinstatement over eight years after the original complaint was filed.

RULING

The Supreme Court dismissed the petition, upholding the respondent court’s order. The legal logic centers on the doctrine of laches, which bars a claim due to unreasonable delay in asserting it, even in labor cases. The original 1963 complaint specifically named only 45 dismissed employees. While it mentioned “more or less 500” members on strike, it did not identify the additional 423 individuals as specific complainants seeking reinstatement. The union waited over six years into the trial—and after settlement negotiations began—to formally seek their inclusion.
This inordinate delay prejudiced the companies’ right to a fair defense, as gathering evidence and witnesses for claims dating back to 1963 would have become exceedingly difficult. The Court reasoned that workers claiming illegal dismissal cannot indifferently wait for years to assert their rights and must seek other employment. The ongoing litigation involving the 45 named workers did not excuse the failure to promptly raise the claims of the 423 others. The policy limiting back wages to three years in protracted cases further underscores the prejudice caused by such delay. Thus, the amendment was barred by laches, and the industrial court did not abuse its discretion in disallowing it.