G.R. No. L-12682. August 31, 1961. SAN MIGUEL BREWERY, INC., and COL. JOSE P. RUEDA, petitioners, vs. PETER C. SANTOS, and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS

Respondent Peter C. Santos was employed intermittently as a temporary security guard by petitioner San Miguel Brewery from December 1952. He became a confidential agent and later a formal member of the SMB Special Police Union. In August 1954, the union filed charges against petitioner Col. Jose Rueda, the company’s Security Officer, with Santos gathering supporting materials. Subsequently, the union recommended Santos for a permanent guard position. Instead of appointment, Santos was subjected to multiple investigations concerning his possession of firearms and was sent for medical examinations. He was diagnosed with a chronic ear condition and was ultimately dismissed on February 3, 1955. Santos filed an unfair labor practice complaint, alleging his dismissal was due to his union activities, particularly his role in the charges against Col. Rueda.
The petitioners denied the charges, asserting that Santos was not a union member, that appointment was a management prerogative, and that the issue was purely personal between Santos and Rueda. The Court of Industrial Relations (CIR) found the petitioners guilty of unfair labor practice. It concluded that the cited medical reason for dismissal was a mere pretext, as Santos was never informed of or treated for the alleged ailment and it never affected his duties. The CIR ordered Santos’s reinstatement with back wages.

ISSUE

Whether the petitioners committed unfair labor practice by dismissing Santos due to his union activities.

RULING

Yes, the Supreme Court affirmed the CIR’s finding of unfair labor practice but modified the reinstatement order. The legal logic centers on the inference of improper motive from circumstantial evidence. While an employer generally need not justify employment decisions, an inference of anti-union animus arises when attendant circumstances create a suspicion of improper motivation, and the employer fails to provide a credible, legitimate reason. Here, the sequence of events was compelling: Santos’s active union role and involvement in charges against Rueda were known to management; his dismissal followed the union’s recommendation for his permanent appointment; and the proffered medical justification was dubious, given the lack of treatment or prior performance issues. These facts, taken together, sufficiently established that Santos’s union activities were the motivating cause for his discharge, constituting unfair labor practice under the law.
However, the Court modified the reinstatement aspect. Santos could only be reinstated to the position he previously held—a temporary security guard—not appointed to a permanent position he never occupied. Reinstatement means restoration to one’s former state. Thus, the decision was affirmed with the modification that Santos be reinstated as a temporary guard, with back wages.