GR L 10170; (April, 1957) (Digest)
G.R. No. L-10170; April 25, 1957
WESTERN MINDANAO LUMBER CO., INC., petitioner, vs. MINDANAO FEDERATION OF LABOR and THE COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The Mindanao Federation of Labor filed a case with the Court of Industrial Relations (CIR) against Western Mindanao Lumber Co., Inc. concerning the dismissal of three employees: Vicente Manuel, Cirilo Manuel, and Hermenegildo (Gil) Santos. The CIR found that Vicente and Cirilo Manuel were only partly responsible for the breakage of company truck parts due to negligence in lubrication, but that the breakage was also attributable to the bad condition of the roads. The CIR held their dismissal was too severe and ordered a six-month suspension followed by reinstatement. The CIR also found the dismissal of Hermenegildo Santos unjustified, as he was dismissed merely for refusing to sign a document incriminating his co-employees, and ordered his reinstatement with back pay. In a supplementary decision, the CIR denied the company’s counterclaim for damages but authorized deductions from the back wages of the Manuel brothers for the loss suffered by the company and for their earnings during the lay-off period. The company petitioned for review.
ISSUE
1. Whether the CIR acquired jurisdiction over the case.
2. Whether the CIR had the authority to order the reinstatement of Vicente and Cirilo Manuel after finding them negligent.
3. Whether the evidence warranted the finding that Hermenegildo Santos was dismissed without just cause.
4. Whether the claimants’ employment elsewhere during the dispute barred their reinstatement.
5. Whether the valuation of the damaged truck parts by the CIR was correct.
RULING
1. The CIR validly acquired jurisdiction. The union’s collective action to vindicate the rights of the dismissed employees posed a danger of a strike, and the CIR had the power to act to forestall such an event. Furthermore, the company had previously voluntarily dismissed an earlier petition for review, which constituted a virtual admission of the CIR’s jurisdiction.
2. The CIR had the authority to order reinstatement. The power of the CIR to reduce excessive punishments meted out to erring employees is well-recognized. Unlike previous cases where dismissed workers were guilty of deliberate misfeasance or where gross negligence was the sole cause of injury, here the negligence of the Manuel brothers was only a contributory factor, with the bad road condition also being responsible. The CIR did not abuse its discretion in finding dismissal unjustified and ordering reinstatement after suspension.
3. The finding that Hermenegildo Santos was dismissed without just cause is binding. The findings of fact of the CIR are conclusive and not subject to review. The absence of a formal dismissal letter does not negate the finding that he was in fact dismissed.
4. The claimants’ provisional employment elsewhere does not bar reinstatement. A dismissed laborer cannot be expected to remain idle, and such employment is a temporary expedient. The CIR correctly ordered that earnings during the lay-off be deducted from the back salaries due.
5. The valuation of the damaged truck parts by the CIR is a question of fact, and its findings on this matter are binding.
The decision of the CIR was affirmed.
