G.R. No. L-23266; April 25, 1968
Laguna Transportation Employees Union, et al., petitioners, vs. Laguna Transportation Co., Inc., respondent.

FACTS

The petitioners, Vicente Marfil, Pedro Alinsod, and Glicerio Artes, members of the Laguna Transportation Employees Union, filed an unfair labor practice complaint against the respondent company. They alleged they were dismissed (Marfil and Alinsod on June 30, 1958, and Artes on December 28, 1958) for refusing to disaffiliate from the union despite promises of salary increases and promotions. Alinsod claimed he was paid only P4 a day due to his union activities while new non-union dispatchers received higher pay. The union had been overwhelmingly defeated in a certification election in April 1958. The respondent company denied the charges, asserting just causes for dismissal: Marfil for habitual tardiness, sleeping on duty, and failure to submit reports due to gambling; Alinsod for always being out of his place of work; and Artes for never being rehired after the company’s incorporation in 1956 due to old age (he was 63), thus lacking an employer-employee relationship. The Court of Industrial Relations (CIR) dismissed the complaint, finding the dismissals were for just cause and not due to union activities.

ISSUE

Whether the Court of Industrial Relations erred in dismissing the unfair labor practice complaint, specifically in finding that the dismissals of petitioners Vicente Marfil, Pedro Alinsod, and Glicerio Artes were for just cause and not due to their union affiliation or activities.

RULING

The Supreme Court affirmed the judgment of the Court of Industrial Relations. The Court held that there was substantial evidence to support the CIR’s findings. For Marfil, evidence showed habitual tardiness, sleeping on duty, and failure to submit reports. For Alinsod, evidence showed he was always out of his place of work. These constitute valid causes for dismissal such as inefficiency, negligence, and lack of interest. For Artes, the CIR found he was never rehired after incorporation due to old age, making him unfit as a driver for a common carrier, and thus no employer-employee relationship existed. The Supreme Court emphasized that its review is limited to whether the CIR’s findings are supported by substantial evidence, which they were. Since valid causes for dismissal existed, no unfair labor practice could be attributed to the respondent company.