GR L 15363; (July, 1961) (Digest)
G.R. No. L-15363. July 31, 1961.
NATIONAL LABOR UNION, petitioner, vs. INSULAR-YEBANA TOBACCO CORPORATION, respondent.
FACTS
The National Labor Union filed unfair labor practice charges against Insular-Yebana Tobacco Corporation in the Court of Industrial Relations (CIR), alleging the discriminatory dismissal of employees Juana Torres, Dominador Gonzales, and Honorato Gabriel due to their union activities. After a hearing, CIR Judge Arsenio I. Martinez found no evidence that the dismissals were motivated by union activity. For Torres, while her dismissal was “not completely justified,” the issue was the cause, not the sufficiency of the grounds. For Gonzales, the dismissal was due to a personal quarrel. For Gabriel, his work ceased because his machine broke down and was not repaired for legitimate business reasons. Judge Martinez recommended dismissing all complaints. On en banc review, the majority sustained this dismissal. However, a minority dissent argued that since the dismissals of Torres and Gonzales were not fully justified and the offenses trivial, they should be reinstated with back wages under the CIR’s general powers.
ISSUE
In an unfair labor practice proceeding under Republic Act No. 875 where the employer is exonerated from the charge of discriminatory dismissal, may the CIR nevertheless order the reinstatement of the dismissed employee on the ground that the dismissal was “not justified”?
RULING
No. The CIR has no such power in this context. The Court, through Justice Labrador, held that the cases were expressly instituted as unfair labor practice cases under Section 5 of the Industrial Peace Act ( R.A. No. 875 ). The jurisdiction invoked was specifically for the prevention of unfair labor practices. Since the CIR found no unfair labor practice was committed—the dismissals were not due to union activity—its authority under the specific statutory grant was exhausted. It could not, after dismissing the charges, invoke its broader general powers under Commonwealth Act No. 103 (which authorizes remedies like reinstatement for dismissals found “not justified”) to grant relief. To rule otherwise would allow the CIR to assume general jurisdiction over all dismissal cases under the guise of an unfair labor practice complaint, even after finding the central allegation of anti-union discrimination unproven. The law provides separate remedies, and the chosen avenue of an unfair labor practice charge confines the court’s inquiry and relief to that specific cause of action. Consequently, the majority of the CIR correctly dismissed the charges without ordering reinstatement or back pay.