G.R. No. L-64183, September 15, 1983
NATIONAL FEDERATION OF LABOR, ET AL., Petitioners, v. THE HONORABLE MINISTER OF LABOR AND EMPLOYMENT, THE NATIONAL LABOR RELATIONS COMMISSION, and ZAMBOANGA WOOD PRODUCTS, INC., Respondents.

FACTS

The petitioners, eighty-one striking employees of respondent Zamboanga Wood Products, Inc., filed this mandamus proceeding after the company refused to readmit them to work. The refusal persisted despite a valid order from the Minister of Labor, Blas F. Ople, which certified the labor dispute for compulsory arbitration. The certification order, issued pursuant to Article 264(g) of the Labor Code, explicitly mandated that “all striking workers… must return to work immediately and Management shall accept all returning workers under the same terms and conditions prevailing previous to the work stoppage.” The petitioners duly notified the company of their intent to return, but the respondent employer ignored both the notification and the ministerial order. The Minister of Labor subsequently denied the company’s motion for reconsideration, reiterating the mandatory and immediate nature of the return-to-work directive.

ISSUE

The core issue is whether the respondent company can be compelled by mandamus to comply with the Minister of Labor’s return-to-work order issued in a certified labor dispute.

RULING

The Supreme Court granted the petition for mandamus. The legal logic is anchored on the compulsory and executory nature of a return-to-work order issued following the certification of a labor dispute. Article 264(g) of the Labor Code is clear and mandatory: when a dispute is certified for arbitration, any striking employees “shall immediately return to work and the employer shall immediately resume operations and readmit all workers under the same terms and conditions prevailing before the strike.” The Court emphasized that such an order is issued in the exercise of the state’s compulsory arbitration power to preserve the status quo and halt the disruptive effects of a strike on an industry. Citing the precedent in Philippine Air Lines Employees Association (PALEA) v. Philippine Air Lines, Inc., the Court ruled that the order must be obeyed immediately upon issuance; its effectivity cannot be deferred pending reconsideration, as this would defeat its very purpose. The respondent company’s act of seeking arbitration while simultaneously defying the concomitant return-to-work order was an inconsistency that could not be countenanced. The Court ordered the immediate implementation of the return-to-work order, directing the company to readmit the petitioners. Matters concerning back wages and seniority rights were left for determination in the ongoing arbitration proceedings.