JOHN I. NEVANS, VICTOR M. NALUS and LUZON BROKERAGE COMPANY, INC., petitioners, vs. COURT OF INDUSTRIAL RELATIONS, LUZON BROKERAGE SUPERVISORS’ UNION (PTGWO) and GUILLERMO STA. ANA, respondents.
FACTS
Respondent Guillermo Sta. Ana was an employee of petitioner Luzon Brokerage Company, Inc., having worked there from September 1953 until his suspension on August 24, 1960, and subsequent dismissal on September 23, 1960. He held the position of Head Checker. Sta. Ana had a history of union activities, joining the Luzon Brokerage Employees Association in 1953, serving as a special observer by 1955, and becoming a member of its board of directors by 1957. On March 8, 1960, he joined the Luzon Brokerage Supervisors’ Union. The suspension and dismissal arose from an incident on August 11, 1960, where, under Sta. Ana’s supervision, four cases of merchandise were loaded onto a company truck. One case was unloaded by his order at the company offices, and the remaining three, with a gate pass he supplied, were delivered to the consignee, Shurdut Mill Supply & Co. It was later reported that one case containing valuable saw teeth was missing. Sta. Ana, along with the truck driver and other employees, was investigated by the police. The company suspended him indefinitely, citing his suspected implication in the case, and later dismissed him for cause, citing his implication in pilferages and other negligences. Respondents filed a complaint for unfair labor practice, alleging the suspension and dismissal were due to Sta. Ana’s union activities. The Court of Industrial Relations found petitioners guilty and ordered Sta. Ana’s reinstatement with backpay. Petitioners sought review, arguing the CIR erred in denying their motion for reconsideration and new trial, in finding unfair labor practice, and in holding individual petitioners Nevans and Nalus liable for back wages.
ISSUE
Whether the Court of Industrial Relations erred in finding that petitioners committed unfair labor practice by suspending and dismissing Guillermo Sta. Ana due to his union activities.
RULING
The Supreme Court reversed the decision and resolution of the Court of Industrial Relations and dismissed the complaint for unfair labor practice. The Court held that the evidence did not substantially support the conclusion that Sta. Ana’s dismissal was due to his union activities. The record showed Sta. Ana’s union activities began in 1953 and were known, yet he received promotions and salary increases in 1959 and 1960, indicating no prior animosity. The alleged 1957 incident with petitioner Nalus, concerning the non-hiring of a recommendee, was rooted in a personal accommodation issue, not union activities, and was followed by positive personnel actions towards Sta. Ana. The Court found no direct or strong circumstantial evidence that union activities were the motive for the disciplinary action. Instead, petitioners had reasonable grounds to believe Sta. Ana was implicated in the pilferage based on the police investigation, which pointed to him as mainly responsible. The issue was the motive for dismissal, not proof of theft, and the circumstances provided probable cause for the company’s action to protect its reputation and as a deterrent. The individual petitioners, Nevans and Nalus, were acting as agents of the company, but since the unfair labor practice charge was dismissed, the issue of their personal liability was moot.
