GR L 11938; (May, 1962) (Digest)
G.R. No. L-11938; May 18, 1962
LA CAMPANA STARCH & COFFEE FACTORY, ET AL., petitioners, vs. KAISAHAN NG MGA MANGGAGAWA SA LA CAMPANA (KKM), ET AL., respondents.
FACTS
The case originated from a labor dispute certified to the Court of Industrial Relations (CIR) in 1951. The CIR ruled that La Campana Starch Factory and La Campana Coffee Factory constituted a single entity. During the pendency of the main case and several incidental petitions for reinstatement and contempt, the owner-manager, Ramon Tantongco, died. The CIR ordered the inclusion of the estate administrator, Ricardo Tantongco, as a party respondent. The administrator moved to dismiss, arguing the money claims should be filed in the probate court, but the CIR denied this. The CIR subsequently rendered a partial decision finding the company guilty of unfair labor practice and ordering reinstatement with back wages. The administrator’s prior appeals to the Supreme Court (G.R. Nos. L-12355 and L-13119) challenging the inclusion order and the denial of the motion to dismiss were dismissed.
ISSUE
The primary issue is whether the CIR orders, particularly the reinstatement and back wage awards, are enforceable against the administrator of the deceased owner’s estate.
RULING
The Supreme Court dismissed the petition, affirming the CIR’s orders. The Court held that the question of the administrator’s liability was already settled with finality in the previous cases (G.R. Nos. L-12355 and L-13119), making the matter res judicata. The Court reiterated that the money claims for back wages were merely incidental to the primary relief of reinstatement for unjust dismissal, which falls within the CIR’s continuing jurisdiction to remedy unfair labor practices and ensure industrial peace. The Court rejected the argument that enforcement against the estate violated due process, as the administrator was properly included as a party and had the opportunity to be heard. Furthermore, the petitioners’ contention regarding a collective bargaining agreement was deemed a factual question not reviewable in the certiorari proceeding. The Court emphasized the CIR’s authority to compel compliance with its reinstatement orders to give effect to its constitutional and statutory mandate over labor disputes.