G.R. No. L-17037 April 30, 1966
THE EAST ASIATIC CO., LTD., E. JAKOBSEN, P. H. SORENSEN and K.R. NIELSEN, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, THE EAST ASIATIC CO. EMPLOYEES’ UNION (PTUC) and SOLEDAD A. DIZON, respondents.

FACTS

The East Asiatic Co., Ltd., its managers E. Jakobsen and K.R. Nielsen, and assistant manager P.H. Sorensen (petitioners) were charged before the Court of Industrial Relations (CIR) with unfair labor practice by The East Asiatic Co. Employees’ Union and its member, Soledad A. Dizon. The charge alleged that Dizon was dismissed due to her union activities. Petitioners denied this, asserting her dismissal was for inefficiency, grave discourtesy, and usurious practices. Dizon had been an employee since 1951, working as a secretary in various departments. The union was organized and registered in March 1958, with Dizon as a member, and presented a collective bargaining demand to the company in April 1958. The incident leading to dismissal began on August 28, 1958, when Sorensen assigned Dizon to prepare letters of credit and an offer. Conflicts arose regarding her completion of this work and her conduct on August 30, where Sorensen claimed she threw papers and shouted, while Dizon claimed she was reproached for inefficiency and union activities. Subsequently, on September 4 and 6, managers Jakobsen and Nielsen pressured her to resign, implying it was due to union activities, and ultimately presented her a dismissal letter effective September 1, 1958. The CIR Judge found petitioners guilty of unfair labor practice and ordered Dizon’s reinstatement with back wages. The CIR en banc affirmed the decision. Petitioners appealed, arguing denial of due process for not being allowed to orally argue their motion for reconsideration and contesting the finding of unfair labor practice.

ISSUE

1. Whether the due process clause was violated when petitioners were refused leave to argue orally their motion for reconsideration before the CIR en banc.
2. Whether the CIR committed grave error in finding petitioners guilty of unfair labor practice.

RULING

1. No, the due process clause was not violated. The Supreme Court ruled that hearing oral arguments on a motion for reconsideration rests within the sound discretion of the court. The CIR’s refusal did not constitute an abuse of discretion, as it noted the parties’ memoranda contained exhaustive arguments sufficient for adjudication. There was no violation of due process.
2. No, the CIR did not commit grave error. The Supreme Court affirmed the CIR’s findings of fact, which are conclusive if supported by some evidence in the record. The Court deferred to the trial judge’s assessment of witness credibility and found evidence supporting the conclusion that Dizon’s dismissal was due to her union activities and not for just cause. The Court noted that her alleged inefficiency was not habitual, she had received yearly salary increases indicating satisfactory service, and the fault-finding coincided with her union involvement. Therefore, the order for reinstatement with back pay was correct. The judgment was affirmed.