G.R. No. L-5735 October 29, 1953
MARCELO RUBBER & LATEX PRODUCTS, INCORPORATED, petitioner, vs. THE HONORABLE COURT OF INDUSTRIAL RELATIONS, THE UNITED RUBBER WORKERS’ UNION, ALEJANDRA BUENAVENTURA, TIMOTEO GUTIERREZ and ESPERANZA TIANGCO, respondents.

FACTS

Petitioner Marcelo Rubber & Latex Products, Inc. is a domestic corporation employing laborers who are members of respondent United Rubber Workers’ Union. On January 25, 1949, a labor dispute arose. The Union claimed the company locked out its workers after rejecting a demand for a general wage increase, while the company claimed the workers staged an unlawful strike. The Court of Industrial Relations (CIR) issued a return-to-work order on February 1, 1949. Subsequently, three union members—Alejandra Buenaventura, Timoteo Gutierrez, and Esperanza Tiangco—allegedly faced unfair labor practices: Buenaventura was suspended for violating factory rules, Gutierrez was assigned strenuous work unsuitable to his physical condition (having previously lost four fingers), and Tiangco was told to leave after being admonished for being away from her post. Their protests led to another strike on March 11, 1949. The company filed an urgent motion to declare the striking workers in contempt and dismiss them. On March 22, 1949, a “Judicial Compromise” was entered into between the company and Servando de los Angeles, purporting to be the Union president, agreeing to dismiss 25 listed workers, including the three respondents, and approving the hiring of replacements. The CIR approved this compromise on March 25, 1949. However, a manifestation was later filed by Conrado Pilapil and 43 other laborers claiming de los Angeles and his attorney entered into the compromise without the knowledge and consent of the union members, and that representation for the dispute was vested in a Negotiating Committee chaired by Pilapil. The CIR, in a decision and resolution, ordered the reinstatement of the three workers with back pay, finding their original suspensions or dismissals improper. The company appealed.

ISSUE

Whether the Court of Industrial Relations erred in ordering the reinstatement of Alejandra Buenaventura, Timoteo Gutierrez, and Esperanza Tiangco with back pay, despite the existence of a Judicial Compromise agreement that sanctioned their dismissal.

RULING

The Supreme Court modified the decision of the Court of Industrial Relations. It held that the reinstatement of the three workers was premature. The Court found that the propriety of their original suspensions or dismissals was correctly determined by the CIR, and under ordinary circumstances, reinstatement would be in order. However, the validity of the subsequent Judicial Compromise, which approved their dismissal, was a pivotal and unresolved issue. The complete determination of the case depended on whether Servando de los Angeles had the lawful authority to represent the Union in entering the compromise, or if, as claimed by other members, the Negotiating Committee chaired by Conrado Pilapil was the proper representative. If de los Angeles was not duly authorized, the compromise would be ineffective and reinstatement proper. If he was authorized, the compromise was valid and the dismissals were lawful. Therefore, the Supreme Court ordered that the reinstatement be held in abeyance pending the CIR’s determination of the legality of the Judicial Compromise based on the issue of proper representation. No costs were awarded.