The Supreme Court ruled that an employer can legally terminate employees who commit illegal acts during a strike, even without a separate petition declaring the strike illegal, if a prior National Labor Relations Commission (NLRC) decision already established the illegality of those acts. This decision emphasizes that employers can act on prior NLRC findings to protect their operations from unlawful obstruction during labor disputes.

Union’s Picket or Employer’s Prerogative: Striking a Balance in Labor Disputes

This case arose from a labor dispute between Jackbilt Industries, Inc. (petitioner) and its employees’ union, Jackbilt Employees Workers Union-NAFLU-KMU (respondent). In 1998, due to economic difficulties, Jackbilt temporarily halted its concrete hollow block production, leading to a strike by the union, which alleged anti-union motivations. During the strike, union members obstructed access to Jackbilt’s premises. Jackbilt filed a petition for injunction with the NLRC, which issued a Temporary Restraining Order (TRO) against the union. However, the union continued to obstruct entry and exit, leading the NLRC to issue a writ of preliminary injunction and subsequently a decision finding the union guilty of obstructing free access. Following this, Jackbilt terminated the officers and members of the union who participated in the strike. The union then filed complaints for illegal lockout, unfair labor practice, and illegal dismissal.

The Labor Arbiter initially dismissed the complaints for illegal lockout and unfair labor practice but found Jackbilt guilty of illegal dismissal, arguing that the company should have filed a petition to declare the strike illegal before terminating the employees. The NLRC modified this decision, holding only Jackbilt liable for the monetary awards. The Court of Appeals (CA) further modified the NLRC decision, finding Jackbilt guilty of unfair labor practice and ordering the payment of backwages and separation pay. The CA reasoned that the temporary shutdown was motivated by anti-union sentiments. Jackbilt then elevated the case to the Supreme Court, questioning whether filing a petition to declare a strike illegal is a prerequisite for validly terminating employees who committed illegal acts during the strike.

The Supreme Court anchored its decision on the principle of conclusiveness of judgment, as outlined in Section 47(c), Rule 39 of the Rules of Court. This principle dictates that parties are bound by findings in a previous judgment regarding matters actually raised and adjudged. The Court highlighted that Article 264(e) of the Labor Code explicitly prohibits obstructing free ingress to and egress from an employer’s premises during picketing.

Article 264(e) of the Labor Code prohibits any person engaged in picketing from obstructing the free ingress to and egress from the employer’s premises.

Since the NLRC had already determined in its July 17, 1998 decision that the union obstructed access to Jackbilt’s facility, the Supreme Court held that the union members had committed illegal acts during the strike. This prior determination was crucial.

The Court emphasized that the use of unlawful means during a strike renders it illegal. Because the NLRC had already established the illegality of the union’s actions, the Supreme Court concluded that the March 9, 1998 strike was ipso facto illegal, making a separate petition to declare it so unnecessary. This point is critical in understanding the Court’s rationale. The prior finding of illegal acts served as sufficient basis for the subsequent dismissals.

Furthermore, the Supreme Court cited Article 264 of the Labor Code, which allows an employer to terminate employees who commit illegal acts during a strike. This provision provides the legal basis for the employer’s action. The Court acknowledged that while the Labor Code uses the word “may,” granting the employer discretion, Jackbilt was within its rights to terminate the employees given the NLRC’s prior finding of illegal acts.

Article 264 of the Labor Code further provides that an employer may terminate employees found to have committed illegal acts in the course of a strike.

The Supreme Court reversed the CA’s decision, effectively upholding the legality of the dismissals. This decision underscores the importance of adhering to legal procedures during strikes and the consequences of engaging in unlawful activities, such as obstructing access to company premises. The ruling also clarifies that employers can rely on prior NLRC findings to justify disciplinary actions against employees who violate labor laws during strikes.

In essence, the Supreme Court’s decision underscores the delicate balance between the rights of workers to strike and the rights of employers to protect their property and business operations. By affirming Jackbilt’s right to terminate employees who engaged in illegal acts during the strike, the Court reinforced the principle that strikes must be conducted within the bounds of the law.

FAQs

What was the key issue in this case?	The central issue was whether an employer must file a separate petition to declare a strike illegal before terminating employees who committed illegal acts during that strike, especially when the illegality of those acts had already been established by the NLRC.
What did the Supreme Court decide?	The Supreme Court ruled that a separate petition to declare the strike illegal was unnecessary because the NLRC had already found that the union committed illegal acts during the strike. Therefore, the employer was justified in terminating the employees.
What is the principle of conclusiveness of judgment?	The principle of conclusiveness of judgment, as embodied in Section 47(c), Rule 39 of the Rules of Court, states that parties are bound by the findings in a previous judgment regarding matters actually raised and adjudged. This means that if an issue has been decided in a prior case, it cannot be relitigated in a subsequent case between the same parties.
What are some examples of illegal acts during a strike?	Illegal acts during a strike can include violence, coercion, intimidation, and obstructing free ingress to or egress from the employer’s premises. In this case, the obstruction of access to Jackbilt’s facility was the primary illegal act.
What does the Labor Code say about terminating employees who participate in illegal strikes?	Article 264 of the Labor Code allows an employer to terminate employees who knowingly participate in the commission of illegal acts during a strike. However, mere participation in a lawful strike is not sufficient grounds for termination.
What was the basis for the Court of Appeals’ decision?	The Court of Appeals found Jackbilt guilty of unfair labor practice, reasoning that the temporary shutdown was motivated by anti-union sentiments. They ordered the payment of backwages and separation pay to the dismissed employees.
Why did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the Court of Appeals’ decision because it found that the NLRC had already determined that the union committed illegal acts during the strike, justifying the employer’s decision to terminate the employees. The Court emphasized that the prior finding of illegal acts served as sufficient basis for the dismissals.
What is the significance of Article 264(e) of the Labor Code in this case?	Article 264(e) of the Labor Code is significant because it prohibits any person engaged in picketing from obstructing the free ingress to or egress from the employer’s premises. This provision was the basis for the NLRC’s finding that the union committed illegal acts during the strike.

This case clarifies the circumstances under which an employer can terminate employees for illegal acts committed during a strike without first obtaining a formal declaration of illegality of the strike itself. The ruling emphasizes the importance of respecting legal boundaries during labor disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Jackbilt Industries, Inc. vs. Jackbilt Employees Workers Union-NAFLU-KMU, G.R. Nos. 171618-19, March 13, 2009