Philippine Sheet Metal Workers Union vs CIR

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Philippine Sheet Metal Workers Union vs CIR
G..R. No. L-2028
April 28, 1949

Facts:

This is a petition for certiorari to review an order of the Court of Industrial Relations on the ground that the same was rendered in excess of jurisdiction and with grave abuse of discretion.

On March 1, 1985, the respondent Union filed a Notice of Strike with the Bureau of Labor Relations (BLR) on ground of unfair labor practice consisting of alleged refusal to bargain, dismissal of union officers/members; and coercing employees to retract their membership with the union and restraining non-union members from joining the union.

The said order was issued of said court involving an industrial dispute between the respondent company (a corporation engaged in the manufacture of tin plates, aluminum sheets, etc.) and its laborers some of whom belong to the Philippine Sheet Metal Workers' Union (CLO) and some to the Liberal Labor Union.

The dispute was over certain demands made upon the company by the laborers, one of the demands, being for the recall of eleven workers who had been laid off. Temporarily taken back on certain conditions pending final determination of the controversy, these eleven workers were in the end ordered retained in the decision handed down by the court on February 19, 1947.

The petitioner tried to prove that the 11 laborers were laid off by the respondent company due to their union activities.

On February 10, 1947, that is, nine days before the decision came down, filed a motion in the case, asking for authority to lay off at least 15 workers in its can department on the ground that the installation and operation of nine new labor-saving machines in said department had rendered the services of the said workers unnecessary.

Issue:

W/N the firing of the laborers due to their union activities is valid?

Held:

Yes. The right to reduce personnel should, of course, not be abused. It should not be made a pretext for easing out laborers on account of their union activities. But neither should it be denied when it is shows that they are not discharging their duties in a manner consistent with good discipline and the efficient operation of an industrial enterprise.

The petitioner contends that the order complained of was made with grave abuse of discretion and in excess of jurisdiction in that it is contrary to the pronouncement made by the lower court in its decision in the main case where it disapproved of the dismissal of eleven workers "with whom the management is displeased due to their union activities." It appears, however, that the pronouncement was made upon a distinct set of facts, which are different from those found by the court in connection with the present incident, and that very decision, in ordering the reinstatement of the eleven laborers, qualifies the order by saying that those laborers are to be retained only "until the occurrence of facts that may give rise to a just cause of their laying off or dismissal, or there is evidence of sufficient weight to convince the Court that their conduct is not satisfactory."

After a careful review of the record, we find that the Court of Industrial Relations has neither exceeded its jurisdiction nor committed grave abuse of discretion in rendering the order complained of. The petition for certiorari is, therefore, denied, but without costs against the petitioner for the reasons stated in its motion to litigate as pauper.