GR L 20303; (September, 1967) (Digest)
G.R. No. L-20303 September 27, 1967
REPUBLIC SAVINGS BANK (now REPUBLIC BANK), petitioner, vs. COURT OF INDUSTRIAL RELATIONS, ROSENDO T. RESUELLO, BENJAMIN JARA, FLORENCIO ALLASAS, DOMINGO B. JOLA, DIOSDADO S. MENDIOLA, TEODORO DE LA CRUZ, NARCISO MACARAEG and MAURO A. ROVILLOS, respondents.
FACTS
The petitioner Republic Savings Bank (Bank) dismissed eight respondent employees on July 12 and 18, 1958. The dismissal was based on the employees having written and published a letter dated July 9, 1958, addressed to the bank president, demanding his resignation. The letter accused the president of immorality, nepotism, favoritism, discrimination in promotions, and tolerating dishonesty and anomalies within the Bank. Copies were given to the chairman of the bank’s board and the Governor of the Central Bank. The Bank characterized the letter as “patently libelous.” The respondents filed a complaint with the Court of Industrial Relations (CIR), alleging the dismissal constituted unfair labor practice under Section 4(a)(5) of the Industrial Peace Act (Republic Act 875) for being dismissed for having filed charges. The Bank moved to dismiss, arguing the discharge was for cause (the libelous letter) and not for union activity.
ISSUE
Whether the dismissal of the eight respondent employees by the petitioner Bank constituted an unfair labor practice under the Industrial Peace Act.
RULING
Yes, the dismissal constituted an unfair labor practice. The CIR found the Bank guilty and ordered reinstatement with full back wages, which decision was affirmed by the court en banc. The Supreme Court upheld this ruling. The Court held that even assuming the respondents acted in their individual capacities, they were engaged in a protected concerted activity for mutual aid and protection, a right encompassed by the right of self-organization under Section 3 of the Act. Interference with this right constitutes an unfair labor practice under Section 4(a)(1). The complaints in the letter regarding nepotism, favoritism, and management practices fell within the proper sphere of collective bargaining. The Bank’s summary dismissal, without attempting to clarify or discuss the claims, was deemed retaliatory and premature. The Court distinguished the case from Royal Interocean Lines, noting the charge need not be strictly “under this Act” as required for Section 4(a)(5), as the conduct was protected under the broader scope of Section 4(a)(1) concerning concerted activities.