G.R. No. L-37952 December 10, 1974
Firestone Filipinas Employees Association, et al., petitioners, vs. Firestone Tire and Rubber Company of the Philippines, Honorable Alberto S. Veloso and Court of Industrial Relations, respondents.

FACTS

Petitioner Firestone Filipinas Employees Association filed an unfair labor practice charge with the Court of Industrial Relations (CIR) against respondent company, alleging union discrimination and harassment of striking employees. While the case (ULP No. 5980) was pending, the then National Labor Relations Commission (NLRC), exercising jurisdiction over strikes overtaken by martial law, facilitated a settlement. This settlement included an agreement to dismiss the pending CIR case.
Subsequently, a lawyer named Raul Espinosa, appearing as counsel of record for the petitioners before the CIR, filed a motion to withdraw the unfair labor practice complaint. This motion was granted by respondent Judge Veloso, leading to the dismissal of the case. The petitioners, however, contended that they never authorized their counsel to file such a motion and were not given an opportunity to be heard on this critical matter, which resulted in the loss of their employment.

ISSUE

Whether the dismissal of the unfair labor practice complaint by the CIR, based on a motion filed by counsel allegedly without the petitioners’ authorization and without affording the petitioners a hearing, violated procedural due process.

RULING

Yes, the dismissal violated procedural due process. The Supreme Court granted the petition for certiorari and set aside the CIR’s order. The Court emphasized the fundamental importance of the right to be heard, especially in labor cases where the stakes involve the workers’ very livelihood. The legal logic proceeds from the constitutional and statutory policy of affording utmost protection to labor.
The Court rejected the argument that the settlement and quitclaims executed before the NLRC constituted a valid bar. Under the prevailing constitutional mandate, the State must assure the rights of workers, and such releases are viewed with caution, especially when alleged to have been secured without proper authorization or a full hearing on the merits. The act of a counsel in moving for dismissal without the client’s express consent, on a matter as vital as an unfair labor practice charge leading to loss of employment, cannot bind the labor union and its members to their prejudice.
Furthermore, the Court noted the advent of the new Labor Code, which reinforced the jurisdiction of a reorganized National Labor Relations Commission. To remand the case for a proper hearing would cause no prejudice but would instead ensure that the petitioners’ grievances are fully ventilated in accordance with the law’s solicitous regard for the workingman. The order of dismissal was therefore annulled, and the case was ordered reinstated for further proceedings to allow the petitioners their day in court.