G.R. No. L-4834 March 28, 1952
LIBERAL LABOR UNION, petitioner, vs. PHILIPPINE CAN COMPANY, respondent.

FACTS

A collective bargaining agreement was entered into between the petitioner Liberal Labor Union and the respondent Philippine Can Company on February 26, 1949, to settle a labor dispute (Case No. 229-V). The agreement established a grievance procedure: (1) submission of any complaint to a six-member grievance committee (three from the union, three from the company); (2) if unresolved, a conference between top officials of both parties; and (3) if still unsettled, submission to the Court of Industrial Relations for determination. On the same day the agreement was concluded, the respondent reduced the wages of seven laborers by P0.50. The petitioner protested to the assistant manager and then the general manager, who on March 5, 1949, stated the management would discuss the matter. Upon returning, union representatives were told the reductions could not be restored and the management would deny them in court. Due to this refusal and the respondent’s failure to name its representatives to the grievance committee (despite the union having designated its members), the union declared a strike on March 14, 1949. The union filed a petition seeking a declaration of the strike’s legality, restoration of the former wage rates, and refund of the wage reductions. The Court of Industrial Relations initially held the strike legal due to the respondent’s failure to designate grievance committee members, but on reconsideration, reversed itself in a resolution dated March 14, 1951, declaring the strike illegal and authorizing the respondent not to rehire those responsible. The petitioner seeks review of this resolution.

ISSUE

Whether the strike staged by the members of the petitioning union on March 14, 1949, is legal and justified.

RULING

The Supreme Court affirmed the resolution of the Court of Industrial Relations, declaring the strike illegal. The Court held that the petitioner violated the terms of the collective bargaining agreement by failing to exhaust the agreed grievance procedure before declaring the strike. While the respondent failed to designate its representatives to the grievance committee, this did not justify an outright strike; the union’s duty was to exhaust all available means, including submitting the dispute to a conference of top officials and, ultimately, to the Court of Industrial Relations, which it failed to do. The agreement’s graduated procedure was designed to prevent strikes and achieve peaceful settlement. Moreover, the strike involved coercion, force, intimidation, physical injuries, sabotage, and the use of obscene language by union officials and members to prevent other laborers from working, which cannot be justified under the law. The resolution appealed from was in accordance with law. The petition was denied, with costs against the petitioner.