G.R. No. L-18336; May 31, 1963
MAGDALENA ESTATE, INC., WILLIAM A. YOTOKO and FELIPE BENABAYE, petitioners, vs. KAPISANAN NG MGA MANGGAGAWA SA MAGDALENA ESTATE, INC., respondent.

FACTS

The respondent union filed an unfair labor practice complaint against the petitioners, alleging that the corporation dismissed 19 union members due to their union affiliation and activities, specifically for refusing to sign a certain application form and for filing charges against the company. The complaint was filed in the name of the union on behalf of these dismissed members. During the trial, only four of the dismissed employees appeared and testified. The Court of Industrial Relations (CIR), through Judge Martinez, found the petitioners guilty of unfair labor practice and ordered the reinstatement with back wages of these four testifying employees. For the 15 other dismissed members who did not testify, the CIR merely suggested they be rehired if openings arose.
The union moved for reconsideration, seeking the same reinstatement remedy for all 19 dismissed members. The CIR en banc granted the motion, ruling that substantial evidence of unfair labor practice existed against all 15 non-testifying employees, and thus ordered their reinstatement with back wages as well. The petitioners appealed, arguing that the relief could not be extended to the 15 members who did not personally appear and testify, as this was not a proper class suit.

ISSUE

Whether the CIR en banc erred in ordering the reinstatement with back wages of the 15 dismissed union members who did not testify during the trial, based substantially on the evidence presented by the four members who did testify.

RULING

The Supreme Court affirmed the CIR en banc’s resolution. The Court held that proceedings before the CIR are not governed by the strict technical rules of ordinary court procedure. Under its charter, the CIR is not bound by technical rules of evidence and may inform itself in a just and equitable manner. The complaint, filed by the union in its name for the benefit of its dismissed members, substantially complied with the requirements of a class suit. The four employees who testified did so not only for themselves but also on behalf of the other 15, establishing a common cause of action based on the petitioners’ unfair labor practice aimed at the union and its members collectively.
The Court found the petitioners’ claim of a retrenchment policy unmeritorious, as the CIR had factually determined this policy was implemented only in the department where the union existed. The dismissal letters’ courteous language also contradicted allegations of dismissal for cause like inefficiency. Since the CIR found substantial evidence of a discriminatory dismissal scheme targeting union members, it was not necessary for each individual to testify. Requiring separate testimony from all 15 would be a useless formality, as the unfair labor practice was established as a collective act against the union. Therefore, the CIR correctly extended the reinstatement remedy to all affected members.