GR L 39154; (September, 1982) (Digest)
G.R. No. L-39154 September 9, 1982
LITEX EMPLOYEES ASSOCIATION and DOMINGO RANCES, petitioners, vs. THE COURT OF INDUSTRIAL RELATIONS, LIRAG TEXTILE MILLS, RAFAEL GALLEMA, ANTONIO LORZANO, ET AL., respondents.
FACTS
Petitioner Domingo Rances, a union board member, wrote a letter dated February 10, 1972, to union president Antonio Lorzano requesting consideration of amendments to the union’s constitution. For this act, the union board charged Rances with violating union rules, expelled him, and recommended his dismissal from Lirag Textile Mills pursuant to the union security clause in the Collective Bargaining Agreement (CBA). The company, upon receiving the recommendation, dismissed Rances after he failed to submit a comment. Following a union election, a new set of officers rescinded Rances’s expulsion and recommended his reinstatement to the company.
The new union leadership formally requested Rances’s reinstatement. Management initially refused, stating the dismissal was final, but later offered to rehire him as a casual employee and subsequently as a regular employee on the condition he admit guilt and forfeit two months’ leave pay. Rances rejected these offers. The petitioners then filed an unfair labor practice charge, which the Court of Industrial Relations (CIR) Prosecutor moved to dismiss for lack of a prima facie case. The CIR granted the motion, a decision affirmed en banc.
ISSUE
Whether the dismissal of Domingo Rances constituted an unfair labor practice.
RULING
Yes, the dismissal was an unfair labor practice warranting Rances’s reinstatement with backwages. The Supreme Court reversed the CIR, holding that Rances was dismissed solely for intra-union activity—writing a letter on union matters—which is protected concerted activity. The legal logic centers on the employer’s bad faith and interference in union affairs. The company’s defense, that it merely acted on the union’s final recommendation under the CBA to maintain stable relations, was contradicted by its own subsequent actions. By offering reinstatement conditional on an admission of guilt and a penalty, the company demonstrated it was not a passive actor but was actively imposing additional punitive conditions unrelated to the original union charge. This interference, coupled with the dismissal’s basis in protected activity, established an unfair labor practice. The Court ordered Rances’s reinstatement under the same terms and awarded three years of backwages without deduction.