G.R. No. L-18778 and L-18779; August 31, 1967
United Seamen’s Union of the Philippines, petitioner, vs. Davao Shipowners Association, Angtiong Sons and/or Ricardo Ang, owner-manager; Angliongto Sons and Company, Garcia Water Transportation, Court of Industrial Relations, et al., respondents.

FACTS

On August 4, 1959, petitioner United Seamen’s Union of the Philippines (USUP) presented demands to respondent Davao Shipowners Association (Shipowners) for union recognition, union security, and standardization of wages and benefits. The Shipowners responded by pointing to an existing collective bargaining agreement (CBA) with the Davao Marine Association (Association), which bound them until the end of 1959, and suggested USUP first seek certification as the collective bargaining agent. Before receiving this answer, USUP filed a notice of strike. A conference led to a covenant dated August 20, 1959, wherein USUP agreed to: (1) withdraw its strike notice; (2) preserve the status quo in business operations; (3) respect the existing CBA until its expiry; and (4) file a petition for a certification election with the Court of Industrial Relations (CIR). USUP complied by filing the petition.
Subsequently, the respondent shipping companies served notices of termination to 64 employees, effective December 31, 1959, citing reasons such as business losses. These employees were members of both USUP and the Association. USUP reported the matter to the Department of Labor and, after an unproductive conference, formally notified authorities of a strike to begin on January 1, 1960.
On February 11, 1960, the Shipowners filed a petition for injunction (Case No. 3-INJ-DB) with the CIR, alleging coercive and violent acts by USUP during the strike. On February 24, 1960, USUP filed an unfair labor practice case (Case No. 49-ULP-DB) against the Shipowners, alleging interference with the right to self-organization and discriminatory dismissal of USUP members. The two cases were tried jointly. The CIR dismissed USUP’s unfair labor practice complaint, declared the strike illegal and unjustified, ordered the dismissal of all active strike participants, and granted a permanent injunction against USUP and its officers from committing specific coercive and obstructive acts. USUP sought review of this decision.

ISSUE

Did the Court of Industrial Relations gravely abuse its discretion in declaring the strike staged by the members of the USUP unjustified and illegal?

RULING

No, the Court of Industrial Relations did not gravely abuse its discretion. The Supreme Court affirmed the CIR’s decision, holding the strike illegal and unjustified.
The Supreme Court found that the strike and the subsequent unfair labor practice case were part of a concerted effort by USUP to compel recognition as the exclusive bargaining agent, despite the existence of a valid CBA with the Association. Several circumstances supported this conclusion: (1) USUP filed its strike notice even before receiving the Shipowners’ answer, indicating a predisposition to strike despite knowing the legal barrier posed by the existing CBA; (2) USUP violated the August 20, 1959 covenant by striking and disturbing the status quo it had agreed to preserve pending the certification election; and (3) the strike was not grounded on any unfair labor practice by the employers, as the termination of the 64 employees was based on legitimate business reasons (e.g., stoppage of operations, business losses) and was a management prerogative recognized under the existing CBA. The Court also noted that the strike involved coercive and violent acts, which rendered it illegal regardless of its purpose. Citing jurisprudence, the Court reiterated that a strike may be declared illegal if its purpose is unjust or if illegal means are employed. Since the strike was illegal, the dismissal of the active participants was a valid consequence, and the grant of a permanent injunction was proper.