GR L 2660; (May, 1950) (Digest)
G.R. No. L-2660; May 30, 1950
LUZON MARINE DEPARTMENT UNION, petitioner, vs. ARSENIO C. ROLDAN, JUAN L. LANTING and MODESTO CASTILLO, Judges of Court of Industrial Relations, LUZON STEVEDORING CO., INC., UNION DE OBREROS ESTIVADORES DE FILIPINAS, and UNIVERSAL MARINE UNION, respondents.
FACTS
Petitioner Luzon Marine Department Union filed a petition with the Court of Industrial Relations (CIR) against respondent Luzon Stevedoring Co., Inc., seeking compliance with twelve demands, including union recognition and a closed-shop agreement. Another union, Union de Obreros Estivadores de Filipinas (U.O.E.F.), intervened, claiming an existing closed-shop agreement with the company. While the CIR was hearing a jurisdictional challenge (regarding whether petitioner had at least 30 members), and before receiving notice of an order denying dismissal, 65 members of petitioner union went on strike on July 19, 1948. The union later filed a petition in the CIR alleging a full strike and seeking a restraining order against the use of strike-breakers. The CIR, en banc, set aside an order by one judge directing reinstatement, ruling the strike was unjustified and illegal.
ISSUE
Was the strike declared by the petitioner union during the pendency of its petition before the Court of Industrial Relations legal and justified?
RULING
No. The Supreme Court affirmed the CIR’s resolution declaring the strike illegal. While Commonwealth Act No. 103 did not expressly prohibit strikes unless enjoined by the CIR, the legality of a strike depends on its purpose and the means employed. Citing prior jurisprudence, the Court held the law does not favor strikes due to their disturbing effects and provides agencies like the CIR to settle disputes. A strike declared for a trivial, unjust, or unreasonable purpose is illegal. Here, the CIR found the strike was called because the company challenged the union’s membership and due to the members’ impatience awaiting the court’s decision—a purpose intended to influence the court’s proceedings, which is unjustified. By resorting to a strike instead of awaiting the legal process, the union acted at its own risk. The affirmed doctrines are: (1) the law discourages strikes due to their pernicious effects and establishes agencies to prevent them; (2) a strike may be declared illegal if for a trivial, unjust, or unreasonable purpose or if carried out through unlawful means; and (3) laborers who strike instead of using legal processes do so at their own risk and face adverse consequences if the strike is found unjustified.
AI Generated by Armztrong.