G.R. Nos. 59012-13 October 12, 1989
RIZAL-MEMORIAL COLLEGES FACULTY UNION-DAVAO WORKERS UNION (RMCFU-DWU), ET AL., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, LEOPOLDO ABELLERA, RIZAL MEMORIAL COLLEGES and RIZAL MEMORIAL COLLEGES FACULTY LEAGUE, respondents.

FACTS

Petitioner Rizal Memorial Colleges Faculty Union (RMCFU) sought direct recognition and collective bargaining from respondent Rizal Memorial Colleges (RMC) in January 1970. Respondent Leopoldo Abellera, RMC President, informed them of a rival union, the Rizal Memorial Colleges Faculty League (RMCFL), making a similar demand. RMCFU filed a petition for direct certification and later staged a strike in March 1970. Subsequently, petitioners filed an unfair labor practice (ULP) case, alleging RMC and Abellera initiated and dominated the RMCFL to bust their union and discriminated against union officers. Petitioners claimed a “return to work agreement” was reached after a meeting on April 4, 1970, wherein Abellera promised no retaliatory measures, job security, and full strike pay, but respondents later refused to sign it. A second strike occurred in June 1970 over alleged dismissals. The consolidated ULP cases were eventually transferred to the National Labor Relations Commission (NLRC).

ISSUE

Whether respondents Rizal Memorial Colleges and Leopoldo Abellera committed unfair labor practice by interfering with the right of petitioners to self-organization, particularly through the dismissal of union members.

RULING

Yes, the Supreme Court found respondents guilty of unfair labor practice. The legal logic centered on the principle that while an employer has the right to dismiss employees for just and authorized causes under Article 283 of the Labor Code, such dismissals become illegal if motivated by the employees’ union activities, constituting interference with the right to self-organization. The Court examined the timing and circumstances of the dismissals of specific petitioners. It found that the termination of twelve petitioners—Felicidad Espino, Patrocinia de Jesus, Francisca Limsiaco, Dulce Saavedra, Raquel Dango, Sylvia Relopez, Loreta Magpantay, Carmen Lauricio, Angelina Tipace, Helen Basug, Amelita Ferido, and Jose Majaducon—occurred during the pendency of the certification election and the labor dispute. Their dismissals closely followed their union activities, including participation in strikes. The Court ruled that the proximity of their union actions to their termination gave rise to a reasonable conclusion that the dismissals were motivated by anti-union sentiment, not valid causes. This constituted a violation of the employees’ right to organize. Consequently, the NLRC decision was modified. The twelve named petitioners were ordered reinstated with three years of backwages. If reinstatement was no longer feasible, they were to receive separation pay of one month’s salary per year of service.