G.R. No. L-1668; March 29, 1948
PHILIPPINE REFINING COMPANY WORKERS’ UNION (CLO) vs. PHILIPPINE REFINING CO.

FACTS

The Court of Industrial Relations (CIR), in an order dated September 26, 1946, directed striking laborers of the Philippine Refining Company to return to work and enjoined them from staging any further strike without the court’s authority, pending final determination of the labor dispute. The company was likewise enjoined from laying off workers or hiring new employees without court approval. Subsequently, the union staged another strike on April 30, 1947. The CIR, in an order dated July 24, 1947, declared this strike illegal and contemptuous for violating its previous order and authorized the company to hire new laborers. The union’s motions for reconsideration were denied. The union petitioned the Supreme Court, challenging the CIR’s orders as issued without jurisdiction, unconstitutional for infringing on workers’ rights and amounting to involuntary servitude, and violative of due process.

ISSUE

1. Whether the CIR had jurisdiction and authority under Commonwealth Act No. 103 , Section 19, to issue the order enjoining a strike and ordering the return to work.
2. Whether such an order constitutes an unconstitutional infringement of workers’ rights and amounts to involuntary servitude.
3. Whether the CIR’s subsequent order (July 24, 1947) and resolutions violated due process.

RULING

The Supreme Court denied the petition and upheld the orders of the CIR.
1. The CIR acted within its jurisdiction and authority under Section 19 of Commonwealth Act No. 103 . The law authorizes the court, after a hearing, to order striking workers to return to work when public interest so requires or when the dispute cannot be promptly decided or settled. The CIR’s September 26, 1946 order was issued after a series of conferences with both parties and was explicitly based on public interest and the court’s opinion that it could not decide the case promptly due to the issues involved. This interpretation aligns with the Court’s prior ruling in *Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas vs. Gotamco Saw Mill* (G.R. No. L-1573).
2. The order does not constitute involuntary servitude or an unconstitutional infringement of rights. By seeking remedy under Commonwealth Act No. 103 before the CIR, the workers voluntarily submitted to the court’s jurisdiction and its reasonable implementing powers, which include prohibiting strikes or ordering a return to work to effectively settle the dispute. The workers are not compelled to continue in repugnant work; they remain free to resign.
3. There was no violation of due process. The CIR’s September 26, 1946 order was issued after a hearing. The subsequent order of July 24, 1947 was based on the union’s violation of that lawful order, and the union was given the opportunity to be heard through its motions for reconsideration.

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