G.R. No. L-17535, December 28, 1961
H. G. HENARES & SONS, petitioner, vs. NATIONAL LABOR UNION, respondent.

FACTS

Pablo Fernandez, a laboratory assistant for H. G. Henares & Sons and a member of the Board of Directors of the company’s employees’ association, was dismissed from his employment. The company’s stated reason for dismissal was an unauthorized exchange of work shifts with a co-employee, Francisco Frio. This exchange was arranged so that Fernandez could testify in a hearing before the Court of Industrial Relations (CIR) in an unfair labor practice case filed against the petitioner company. Fernandez worked Frio’s night shift, and Frio covered Fernandez’s day shift on the date of the hearing, all without prior company approval.
The CIR found the petitioner guilty of unfair labor practice and ordered Fernandez’s reinstatement with back wages. The industrial court concluded that the dismissal was discriminatorily motivated, noting that while both Fernandez and Frio were investigated for the same infraction, only Fernandez was dismissed; Frio merely received a suspension. The CIR found that Fernandez’s action was a minor infraction aimed at avoiding disruption to company operations while fulfilling his duty to testify.

ISSUE

Whether the Court of Industrial Relations erred in finding that the dismissal of Pablo Fernandez constituted unfair labor practice, unsupported by substantial evidence.

RULING

The Supreme Court affirmed the CIR decision, ruling that substantial evidence supported the finding of unfair labor practice. The legal logic centers on the principle that the CIR’s factual findings are conclusive if supported by substantial evidence, which is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The Court held that the company’s proffered reason for dismissal—the unauthorized shift exchange—was a trivial infraction that did not justify the severe penalty of dismissal, especially when the same act by another employee resulted only in suspension. This disparate treatment indicated a discriminatory motive.
Critically, the Court found a nexus between Fernandez’s dismissal and his protected union activities. Fernandez was a union officer and was dismissed barely three days after testifying against the company in another labor case. His shift exchange was directly to facilitate this testimony, which the Court deemed an important task. The company’s claim of a stern disciplinary rule was undermined by evidence that prior authorization for shift exchanges was not always required for urgent matters. The Court rejected the petitioner’s attempt to justify the dismissal by referencing Fernandez’s past infractions, as he had already been punished for those, and the warning for future dismissal did not logically encompass the present minor incident. Therefore, the dismissal was unlawfully motivated by Fernandez’s union activities, constituting unfair labor practice under the Industrial Peace Act. The award of back wages was also upheld as within the CIR’s sound discretion.