GR L 11745; (October, 1960) (Digest)
G.R. No. L-11745; October 31, 1960
ROYAL INTEROCEAN LINES, ET AL., petitioners, vs. HON. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.
FACTS
The petitioner, Royal Interocean Lines, a foreign corporation licensed to do business in the Philippines, employed respondent Ermidia A. Mariano in its Manila branch office from January 5, 1932, until her discharge on October 23, 1953. In October 1953, a strained relationship developed between Mariano and the Manila branch manager, Kamerling. This led Mariano to lodge a complaint against Kamerling with the company’s managing director in Hongkong. Subsequently, Kamerling, with the approval of the head office, dismissed Mariano. She then charged the petitioner and Kamerling with unfair labor practice under Section 4(a), subsection 5 of Republic Act No. 875 before the Court of Industrial Relations (CIR). The CIR found the petitioner and Kamerling guilty and ordered Mariano’s reinstatement with backpay. The petitioner appealed via certiorari.
ISSUE
Whether or not the petitioner was guilty of unfair labor practice under Section 4(a), subsection 5 of Republic Act No. 875 for dismissing the respondent because she had filed charges against the branch manager, when such charges were not connected with or arising from union activities.
RULING
The Supreme Court reversed the decision of the Court of Industrial Relations. It held that the petitioner was not guilty of unfair labor practice.
The Court interpreted Section 4(a), subsection 5 of Republic Act No. 875 , which prohibits an employer from dismissing or discriminating against an employee “for having filed charges or for having given or being about to give testimony under this Act.” The Court ruled that the phrase “under this Act” modifies all three enumerated acts (filing charges, giving testimony, being about to give testimony). Therefore, for a dismissal to constitute unfair labor practice, the charges filed or testimony given by the employee must have reference to or arise from the employee’s rights to self-organization and collective bargaining, which are the fundamental rights protected by the Act (the “Magna Charta of Labor”).
The Court emphasized that while the Act safeguards workers’ rights to organize, it does not interfere with an employer’s inherent right to discipline employees and its normal prerogative to hire or dismiss them. The prohibition is only against using dismissal as an instrument of discrimination or interference due to an employee’s labor or union activities.
In this case, the respondent’s dismissal had no relation to union activities, and the charges she filed against the manager were unrelated to and did not arise from her union activities. Consequently, her dismissal did not constitute unfair labor practice under the law. The CIR’s order for reinstatement with backpay was revoked.