G.R. No. L-39040 June 6, 1990
ROYAL UNDERGARMENT CORPORATION OF THE PHILIPPINES, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, ROYAL UNDERGARMENT WORKERS UNION (PTGWO) and ANTONIO CRUZ, respondents.

FACTS

Antonio Cruz was employed by Royal Undergarment Corporation as an electrician and was elected president of the Royal Undergarment Workers Union (RUWU-PTGWO) in December 1961. Immediately after the union sent collective bargaining proposals to management on December 14, 1961, Cruz and his wife, also an employee, were terminated the following day. This prompted a strike. A Return-to-Work Agreement was later forged, which provided for Cruz’s reinstatement contingent on the union winning a consent election. Cruz was eventually reinstated, indicating the union’s victory, and a collective bargaining agreement was signed in March 1962. In November 1962, during a campaign for a nationwide strike, an incident occurred where Cruz was accused by three supervisory employees of being intoxicated and threatening their lives. After a company investigation, Cruz was dismissed on December 13, 1962, for these alleged infractions.

ISSUE

Whether the dismissal of Antonio Cruz constituted an unfair labor practice, or whether it was a valid exercise of management prerogative for a just cause.

RULING

The Supreme Court affirmed the finding of unfair labor practice. The legal logic hinges on the suspicious timing and the history of antagonism between Cruz’s union activities and the company’s actions. The Court applied the principle that where an employee is dismissed shortly after engaging in protected union activities, and the employer’s stated reason for dismissal is questionable, an inference of anti-union motivation is justified. The factual findings of the Court of Industrial Relations, supported by substantial evidence, established that Cruz’s dismissal was precipitated by his vigorous union leadership, particularly his campaign for the nationwide strike, and not merely by the alleged November 1962 incident. The company’s claim of just cause was deemed a pretext. The Court modified the award of backwages, limiting it to three years from the date of dismissal without deductions, in line with the judicial trend to avoid protracted hearings. Reinstatement with full seniority rights was ordered, or separation pay if reinstatement was no longer feasible. The petition was denied.