GR L 15834; (January, 1961) (Digest)
G.R. No. L-15834; January 20, 1961
NATIONAL FASTENER CORPORATION OF THE PHILIPPINES, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and NATIONAL FASTENER EMPLOYEES ASSOCIATION (PTUC), respondents.
FACTS
The National Fastener Corporation of the Philippines was charged with unfair labor practice before the Court of Industrial Relations (CIR) for dismissing employee Celestino Blas, a union sergeant-at-arms. The complaint alleged the dismissal was intended to discourage union membership and was in retaliation for Blas’s testimony against the company in a prior CIR case. The corporation defended the dismissal, citing Blas’s absenteeism and other work irregularities as just and valid grounds. The CIR’s Presiding Judge initially found the corporation guilty and ordered Blas’s reinstatement without backpay.
Upon motions for reconsideration, the CIR en banc sustained the unfair labor practice finding but modified the order, directing Blas’s reinstatement with back wages. The corporation then filed this petition for certiorari, arguing the CIR abused its discretion in finding unfair labor practice and in awarding backpay, maintaining that Blas’s dismissal was justified.
ISSUE
Whether the Court of Industrial Relations committed grave abuse of discretion in finding the petitioner guilty of unfair labor practice and in ordering the reinstatement of Celestino Blas with back wages.
RULING
The Supreme Court dismissed the petition and affirmed the CIR en banc resolution. The legal logic centered on the standard of review and the sufficiency of evidence. The Court emphasized that findings of fact by the CIR, which had the direct opportunity to examine witnesses and appraise evidence, are accorded respect and finality if supported by substantial evidence. It found such substantial evidence supporting the unfair labor practice charge.
The record contained testimony that management instructed Blas not to affiliate with the union, promised a salary raise for compliance, and warned him that any infraction would lead to dismissal after learning of his union activities and testimony. The Court noted that the superintendent’s report recommending dismissal significantly highlighted Blas’s union membership and the pending case. While the company cited absenteeism as the cause, evidence showed other employees with similar infractions were not dismissed, suggesting discriminatory motive. The Court rejected the petitioner’s argument that it would have targeted more prominent union officials, reasoning such an obvious act would have been riskier.
Regarding back wages, the Court ruled the award was within the CIR’s sound discretion under the Industrial Peace Act. Since the dismissal was found to be an unfair labor practice, reinstatement with backpay was a proper remedial measure. The petition failed to demonstrate a grave abuse of discretion, as the CIR’s decision was sufficiently grounded in credible evidence, not requiring a preponderance thereof for affirmance.