G.R. No. L-3733 July 30, 1951
STANDARD COCONUT CORPORATION, petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS and FELIPE MORALES, ET AL., respondents.

FACTS

On May 13, 1948, the Gumaca Labor Union, a group of workers at the Gumaca plant of Standard Coconut Corporation, presented a petition for wage increases and better working conditions. Negotiations were postponed to May 29, but the plant manager failed to appear, making laborers suspect the company was sidetracking their demands. Officers of the affiliated Congress of Labor Organizations held conferences with the company’s lawyers, and when these failed, the union’s vice-president filed a petition with the Court of Industrial Relations (CIR) on June 5, 1948. This was replaced on July 7 by a petition signed individually by Felipe Morales and 35 others because the unregistered union lacked legal personality.
On June 8, 1948, three days after the dispute was submitted to the CIR, the company’s general foreman, Tomas Trespalacioreal (who was also president of another labor union in the plant), pressured members of the Gumaca Labor Union to join his union under threat of dismissal and transferred laborers without cause. In protest, the union members staged a peaceful strike that day. The strike was called off after a brief negotiation on the understanding that strikers would be reinstated, but the company failed to do so because Trespalacioreal’s union threatened its own strike if the strikers returned. The strikers then petitioned the CIR for reinstatement.
The CIR presiding judge initially denied the petition, ruling the strike was “unjustified but also unreasonable.” However, upon motion for reconsideration, the CIR en banc set aside this resolution, with two judges dissenting. Standard Coconut Corporation appealed.

ISSUE

Whether the strike staged by the members of the Gumaca Labor Union pending determination of their case in the Court of Industrial Relations was unjustified and unreasonable, and therefore illegal.

RULING

The Supreme Court affirmed the CIR en banc resolution, holding the strike was not illegal. The Court noted that while Section 19 of Commonwealth Act No. 103 outlaws a strike only when judicially enjoined, jurisprudence establishes that a strike may be declared illegal if declared for a trivial, unjust, or unreasonable purpose or carried out through unlawful means. Here, the strike did not violate any law or judicial decree and was not carried out through illegal means.
The immediate causes of the strike were: (1) the general foreman pressuring union members to affiliate with his union under threat of dismissal, and (2) the foreman transferring some members to a “floating gang” without fixed work. The Court found these maneuvers, coming after the plant manager’s failure to negotiate, would have led to the absorption and dissolution of the Gumaca Labor Union and the abandonment of its demands. The strike was a reasonable measure to prevent this outcome and preserve their petition before the CIR. Therefore, the strike was not declared for a trivial, unjust, or unreasonable cause and was not illegal. Costs were imposed on the petitioner.