G.R. No. L-59711. May 29, 1987.
PROGRESSIVE WORKER’S UNION AND ITS 3,000 OFFICERS AND MEMBERS, petitioners, vs. HON. FLAVIO P. AGUAS, THE COMMANDING GENERAL, P.C. METROCOM, THE DISTRICT COMMANDER, EASTERN POLICE DISTRICT, METROPOLITAN POLICE FORCE, THE STATION COMMANDER, MUNTINLUPA POLICE STATION, and SOLID MILLS INC., respondents.

FACTS

Petitioner Progressive Workers’ Union, the certified bargaining agent at Solid Mills, Inc., filed a notice of strike alleging unfair labor practice and violation of their Collective Bargaining Agreement (CBA). The dispute centered on the interpretation of a CBA provision granting a ₱1.50 daily wage increase effective January 1, 1980. The union contended the increase should be integrated into the basic wage starting from that date, thereby compounding over the CBA’s three-year term. The company disagreed, having paid it as a separate retroactive lump sum. The Bureau of Labor Relations (BLR) deemed the issue a non-strikeable interpretation of the CBA and advised the union to seek voluntary arbitration. Ignoring this, the union held a strike vote and commenced a strike on February 11, 1982.
On the same day, Solid Mills filed twin petitions with the National Labor Relations Commission (NLRC) to declare the strike illegal and for the dismissal of participating workers. The Labor Arbiter issued an interim order on February 19, 1982, which, among other things, urged striking workers to return to work within 48 hours. The company published a return-to-work notice. The union then filed this special civil action for certiorari and prohibition, seeking to annul the Labor Arbiter’s order and to enjoin further proceedings, arguing lack of jurisdiction under the then-prevailing Batas Pambansa Blg. 130.

ISSUE

Whether the Labor Arbiter had jurisdiction over the complaints for declaration of an illegal strike filed by the company.

RULING

Yes, the Labor Arbiter had jurisdiction. The Supreme Court dismissed the petition. The legal logic is anchored on the provisions of Batas Pambansa Blg. 130, which amended the Labor Code. The law explicitly vested in Labor Arbiters exclusive jurisdiction over all unresolved labor disputes involving workers, whether agricultural or non-agricultural. This broad grant of jurisdiction specifically includes cases involving unfair labor practices and those arising from employer-employee relations. A complaint seeking to declare a strike illegal, with prayers for dismissal of employees and damages, falls squarely within the scope of “unresolved labor disputes” arising from employer-employee relations. The Court clarified that the characterization of the strike’s legality is incidental to the main action for unfair labor practice, over which the Labor Arbiter undeniably had jurisdiction. Therefore, the Labor Arbiter acted within his authority in taking cognizance of the case and issuing the assailed interim return-to-work order, which was a valid exercise of his power to assume jurisdiction over labor disputes affecting national interest or to issue injunctive relief in cases of unfair labor practice.
However, on equitable grounds, the Supreme Court ordered the reinstatement of the dismissed strikers. The Court considered that the company had already reinstated some strikers and entered into a compromise with others in a related case. Applying principles of fairness and to avoid undue hardship, the Court directed Solid Mills to reinstate the employees listed in the Labor Arbiter’s decision to their former positions without backwages. If reinstatement was no longer feasible, the company was ordered to pay separation pay computed from the date of employment up to the strike date, pursuant to the Labor Code or the CBA, whichever was higher. This equitable relief was