GR L 33987; (May, 1979) (Digest)
G.R. No. L-33987 May 31, 1979
LIBERTY COTTON MILLS WORKERS UNION, ET AL. vs. LIBERTY COTTON MILLS, INC., ET AL.
FACTS
Petitioners, members of a local union, disaffiliated from the mother federation, respondent PAFLU, in May 1964 pursuant to their union constitution. PAFLU declared the disaffiliation void, expelled the petitioners for disloyalty, and requested respondent company to dismiss them. The company complied the next day, terminating the petitioners’ employment based on the Maintenance of Membership clause in the Collective Bargaining Agreement (CBA), which bound the company to dismiss members expelled for disloyalty upon PAFLU’s written request and held the company free from liability.
The Court’s initial decision, dated September 4, 1975, ordered the company to reinstate the workers but held only PAFLU liable for paying three years of backwages. The petitioners filed a motion for reconsideration, praying that the company be made jointly liable for backwages and that they be reinstated with full seniority and at current wage rates.
ISSUE
Whether respondent Liberty Cotton Mills, Inc. should be held jointly and severally liable with PAFLU for the payment of backwages to the illegally dismissed workers.
RULING
Yes. The Supreme Court amended its decision, holding the company jointly and severally liable with PAFLU for three years of backwages. The Court found the company acted in bad faith. While the CBA obligated the company to dismiss workers upon PAFLU’s request, this duty was not absolute and had to be exercised with caution, respecting the workers’ constitutional rights to due process, security of tenure, and labor. The company’s dismissal was hasty and summary, effected just one day after PAFLU’s request without any inquiry or hearing afforded to the workers. This immediate compliance, coupled with the company’s swift denial of the workers’ plea for reconsideration, demonstrated a disregard for procedural fairness, transforming a contractual obligation into a tortious act. The company could not hide behind the CBA’s indemnity clause to escape liability for its own culpable conduct. The reinstatement order was also modified: workers must be reinstated at current rates for the same positions, without loss of seniority. The liability for backwages is solidary between the company and PAFLU, but PAFLU is ordered to reimburse the company for any backwages the company pays, upholding the CBA’s indemnity provision as between the respondents.