GR 94372; (June, 1991) (Digest)
G.R. No. 94372; June 21, 1991
Samahang Manggagawa ng Rizal Park and Domingo Enriquez, petitioners, vs. National Labor Relations Commission and National Park Development Committee, respondents.
FACTS
The petitioners were employees of the National Park Development Committee (NPDC). In 1972, after the petitioner union proposed collective bargaining and filed a notice of strike, the individual petitioners were successively dismissed. The uniform reason provided in their termination notices was that their continued employment was “not compatible with the rules of the New Society.” Their complaint for illegal dismissal was initially dismissed by a Labor Arbiter in 1976. On appeal, the National Labor Relations Commission (NLRC), in a decision dated June 29, 1990, affirmed the dismissals on the different ground that the charge of unfair labor practice was not sufficiently proven. The petitioners challenged this NLRC decision via certiorari.
ISSUE
Whether the NLRC committed grave abuse of discretion in upholding the validity of the petitioners’ dismissal.
RULING
Yes. The Supreme Court granted the petition, reversed the NLRC decision, and ordered the reinstatement of the petitioners with five years’ back salaries. The Court clarified that, as a government agency, the NPDC’s employees are governed by civil service rules, placing the dispute outside the primary jurisdiction of the NLRC and the Labor Code. However, the Court opted to resolve the substantive merits directly due to the case’s pendency since 1972 and the completeness of the record. On the merits, the dismissal was patently invalid. The burden of proving the legality of a dismissal rests on the employer. The NPDC failed utterly to discharge this burden. The stated reason—incompatibility with the “rules of the New Society”—was a vague, supercilious, and preposterous justification that indicated no specific cause for termination. The NLRC’s affirmation of such an arbitrary dismissal, long after the fall of the Marcos regime, constituted grave abuse of discretion. The Court condemned the perpetuation of the past regime’s oppressive practices and rectified the injustice.