GR L 4330; (March, 1952) (Digest)
G.R. No. L-4330 March 24, 1952
MANILA ORIENTAL SAWMILL CO., petitioner, vs. NATIONAL LABOR UNION and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
On May 4, 1950, the United Employees Welfare Association (UEWA), a registered union composed of employees of the petitioner, Manila Oriental Sawmill Co., entered into a one-year agreement on working conditions with the petitioner, pursuant to a settlement in Court of Industrial Relations (CIR) Case No. 173-V. On August 14, 1950, thirty-six of the thirty-seven members of UEWA resigned and joined the local chapter of the respondent National Labor Union (NLU), without evidence of the petitioner’s approval of these resignations. The next day, the NLU president sent a letter to the petitioner containing seven demands on behalf of these members. The petitioner replied, through counsel, stating that the laborers in question were affiliated with UEWA. After the NLU reiterated its demands on August 22, the petitioner’s counsel responded that it could not recognize the NLU local chapter unless the existing May 4 agreement was first declared null and void by the CIR. On August 28, 1950, the members of the NLU local chapter went on strike. The petitioner filed a petition with the CIR to declare the strike illegal. On September 8, 1950, the CIR, through Presiding Judge Arsenio Roldan, issued an order denying the petitioner’s prayer and instead set the case for hearing on the NLU’s demands. The petitioner’s motion for reconsideration was denied by the CIR en banc on November 14, 1950, prompting this petition for review.
ISSUE
Whether the strike staged by the members of the respondent National Labor Union is illegal, considering the existence of a valid and subsisting collective bargaining agreement between the petitioner and the union (UEWA) to which the striking employees originally belonged.
RULING
The Supreme Court reversed the order of the Court of Industrial Relations and declared the strike illegal. The Court found that the local chapter of the respondent NLU was composed almost entirely of the same employees who were bound by the valid one-year agreement between the petitioner and the UEWA, which was entered into with the sanction of the CIR. Their resignations from UEWA and transfer to the NLU, done without the petitioner’s approval, were merely a subterfuge to disregard and circumvent their existing contractual obligations. The Court held that such a move subverts the principle of freedom of contract and the good faith required in contractual relations. It cannot be sanctioned, as it would undermine harmonious labor-management relations and industrial peace. The strike staged under these circumstances was therefore declared illegal.