G.R. No. L-18334. August 31, 1963.
FILEMON DIONELA, ET AL., petitioners, vs. THE COURT OF INDUSTRIAL RELATIONS, E. R. SQUIBB AND SONS (PHIL.), and CARLETON ASHLEY, respondents.

FACTS

Prior to this case, a labor union (Gas and Chemical Free Workers) and three specific employees filed an unfair labor practice (ULP) case (No. 598-ULP) against E.R. Squibb and Sons. While that case was pending, the union, including the petitioners herein, declared a strike. The Court of Industrial Relations (CIR) issued a permanent injunction against the strikers due to acts of violence. Subsequently, the union and the corporation reached a compromise agreement to settle all disputes, which included the payment of three months’ separation pay to each striking employee and the withdrawal of the ULP complaint in Case No. 598-ULP.
Petitioners, a minority group within the union, objected to this settlement. They filed a motion in the old case to disauthorize the union and its counsel from representing them, but this was overruled. The complaint in Case No. 598-ULP was then dismissed upon the union’s withdrawal. Unsatisfied, the petitioners instituted a new ULP case (No. 895-ULP), the subject of this appeal, alleging new acts of unfair labor practice and refusal to reinstate them, arguing the compromise was not binding on them as dissenting members.

ISSUE

Whether the compromise agreement entered into by the majority of the union is binding upon the dissenting minority members (the petitioners).

RULING

Yes, the compromise agreement is binding upon all union members, including the dissenting minority. The Supreme Court affirmed the CIR’s dismissal of the petitioners’ new case. The legal logic rests on the fundamental principle of majority rule in collective labor relations, which is essential to industrial peace and the efficacy of collective bargaining. Allowing a minority faction to repudiate a settlement validly entered into by the union’s majority would undermine stability and discourage employers from entering into any agreements, as they could perpetually face subsequent claims from dissenting members. This would defeat the policy of Republic Act No. 875 (the Industrial Peace Act) to promote the amicable settlement of labor disputes.
The Court further held that the petitioners’ new allegations of unfair labor practice, which pertained to events predating the comprehensive compromise agreement, should be deemed included and settled by that agreement. The union cannot be permitted to split its cause of action by filing successive charges based on acts occurring within the same period covered by an earlier, settled dispute. The Court noted the petitioners failed to present evidence for their new allegations. Therefore, the dismissal of the first case barred the subsequent action.