G.R. No. L-37851 August 5, 1980
LUZON GENERAL MERCHANDISING COMPANY and MARIANO GARCIA, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, LUZON GENERAL MERCHANDISING WORKERS UNION — ILMUP, and FILEMON BOCAL, JR., et al., respondents.

FACTS

The case originated from a labor dispute. After failed collective bargaining negotiations where petitioners granted none of the union’s demands, a peaceful strike ensued. The parties subsequently entered into an agreement on July 10, 1968, to hold a consent election on July 13, 1968. Key conditions were the strikers’ return to work within 48 hours and the mutual withdrawal of all cases. The union complied by lifting the picket and reporting for work on July 11. However, petitioners, through their personnel and counsel, repeatedly prevented the strikers from resuming work, instructing them to wait for the election and later informing them they were already dismissed. Consequently, the consent election was not held. The Court of Industrial Relations (CIR) found petitioners guilty of unfair labor practice, specifically for bargaining in bad faith and union-busting by luring the union president into the agreement while intending to dismiss the members.

ISSUE

Whether the Court of Industrial Relations committed reversible error in finding petitioners guilty of unfair labor practice.

RULING

The Supreme Court affirmed the CIR’s decision, with a modification on back wages. The petition, grounded on procedural due process, failed. The legal logic is threefold. First, the factual findings of the CIR, supported by substantial evidence, are conclusive and binding on the Supreme Court. The established facts—the refusal to grant any demand during negotiations, the prevention of the strikers’ return to work despite the agreement, and the subsequent dismissal—clearly constituted bad faith bargaining and an attempt to bust the union, which are classic unfair labor practices under the law. The constitutional mandate for labor protection would be meaningless if such conduct were condoned.
Second, petitioners’ procedural argument that the testifying complainants could only testify for themselves and not for other respondents was rejected. The Court cited established doctrine, notably from Sanchez v. Court of Industrial Relations, that in unfair labor practice cases, a few claimants can validly testify on behalf of all similarly situated complainants. This procedural rule ensures efficient adjudication of collective labor disputes.
Third, the Court modified the award of back wages. While affirming the finding of illegal dismissal, it limited the back wages to three years without qualification, following the prevailing jurisprudential rule at the time to temper the burden on employers while providing relief to employees. The award was deemed immediately executory, eliminating the need for a prior examination of company records. The ruling underscores the Court’s policy to respect factual determinations of labor tribunals and to uphold the rights of labor against manifest bad faith in collective bargaining.