G.R. No. L-24498 September 21, 1968
TANGLAW NG PAGGAWA, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and RED V COCONUT PRODUCTS, LTD., respondents.

FACTS

Petitioner labor union, Tanglaw Ng Paggawa, and respondent company, Red V Coconut Products, Ltd., entered into a collective bargaining agreement in October 1961. A dispute arose over the interpretation of a provision concerning vacation leave pay for mill employees. The union demanded payment under one interpretation, while the company refused, applying a different interpretation. The union also raised a claim regarding night differential pay. Unable to resolve the dispute, the union filed an unfair labor practice complaint (Case No. 3153-ULP) with the Court of Industrial Relations (CIR), alleging that the company’s refusal to comply with the agreement was done in bad faith and caused a depletion in union membership from 800 to around 700 due to resignations. The CIR trial judge found for the union, but the CIR en banc, on the company’s appeal, dismissed the case for lack of jurisdiction. The CIR en banc found no sufficient evidence that the non-enforcement of the agreement caused the resignations, noted the company acted in good faith, and held that the night differential issue had already been decided in a prior case (Case No. 1642-V). The CIR concluded that, absent unfair labor practice, the dispute was merely about interpreting and enforcing the bargaining agreement, a matter for the regular courts. The union’s motion for reconsideration was denied, prompting this petition for review.

ISSUE

Whether the Court of Industrial Relations correctly dismissed the unfair labor practice complaint for lack of jurisdiction, based on its finding that there was no unfair labor practice and the dispute was merely about the interpretation and enforcement of the collective bargaining agreement.

RULING

The Supreme Court affirmed the resolution of the Court of Industrial Relations. The main issue was factual: whether the employer’s conduct was discriminatory and intended to prejudice the union by reducing its membership. The CIR’s negative finding was supported by substantial evidence. The only direct evidence on the resignations was the biased and hearsay testimony of the union vice-president, and the resignation letters submitted did not refer to the bargaining agreement and were dated after the complaint was filed. Unfair labor practice, being in the nature of a criminal offense, must be clearly proved and cannot be presumed from resignations alone. The CIR found no evidence of discrimination, as the company applied its interpretation to all employees irrespective of union affiliation, and the company’s retroactive enforcement of the vacation leave provision from January 1, 1961 (despite the contract’s August 15, 1961 effectivity) negated bad faith. On the night differential claim, even if the company was bound to pay, there was no clear evidence its refusal was intended to prejudice the union. The CIR’s factual findings, being reasonably supported by the record, are binding. In the absence of unfair labor practice, the issue is reduced to a simple divergence of opinion on how to apply the vacation leave agreement, a matter of interpretation and enforcement of contractual stipulations that devolves upon the regular courts, not the CIR. Therefore, the CIR committed no error or abuse of discretion in declining jurisdiction.