GR L 34948; (May, 1979) (Digest)
G.R. No. L-34948-49 May 15, 1979
PHILIPPINE METAL FOUNDRIES INC., petitioner, vs. COURT OF INDUSTRIAL RELATIONS, REGAL MANUFACTURING EMPLOYEES ASSOCIATION REGEMAS and CELESTINO BAYLON, respondents.
FACTS
The petitioner, Philippine Metal Foundries, Inc., filed an unfair labor practice complaint against the respondent union, Regal Manufacturing Employees Association, for staging a strike on October 5, 1963, allegedly in violation of a no-strike clause and grievance procedure in their collective bargaining agreement. The union countered that the strike was a response to the company’s unfair labor practice, specifically the dismissal of its President, Celestino Baylon, on October 3, 1963. In a separate but consolidated case, the union charged the company with unfair labor practice for Baylon’s dismissal, claiming it was due to his union activities. The company defended the dismissal, citing Baylon’s habitual absenteeism as the lawful cause under the CBA and company rules.
ISSUE
The primary issues were: (1) whether Celestino Baylon was dismissed for just cause (absenteeism) or for his union activities; and (2) whether the subsequent strike declared by the union was legal.
RULING
The Supreme Court dismissed the petition, affirming the Court of Industrial Relations’ decision. On the first issue, the Court upheld the finding that Baylon was dismissed due to his union activities, not his absenteeism. While Baylon had a record of absences, the company’s failure to act on earlier, more severe infractions—particularly twelve consecutive absences in March 1963—undermined its claim that absenteeism was the true reason. The timing was critical: Baylon was dismissed just hours after, as Union President, he formally invited management to a grievance conference. This sequence, coupled with evidence of Baylon’s vigorous advocacy for union members’ rights, constituted substantial evidence supporting the conclusion of discriminatory dismissal motivated by union animus.
Regarding the strike’s legality, the Court ruled it was a valid response to an unfair labor practice. A strike declared in good faith belief that the company committed an unfair labor practice—such as the discriminatory dismissal of a union officer—is considered legal, even if it violates a no-strike clause in a CBA. The union’s belief was found to be in good faith, as it was based on the immediate dismissal following a request for negotiations. Consequently, the strike was a protected activity, and the complaint against the union was properly dismissed. The Court reinstated the order for Baylon’s reinstatement with one year of back wages.