The Supreme Court ruled that a strike, though initiated a day early, was justified due to the employer’s lockout of union members, emphasizing that procedural rules should not overshadow the pursuit of substantial justice. This decision underscores the importance of protecting workers’ rights to organize and protest unfair labor practices. It serves as a reminder that the strict application of procedural rules should not hinder the fair resolution of labor disputes, especially when employers’ actions provoke premature strike actions.

Lockout or Not? The Premature Strike Dilemma

PMI Colleges Bohol and its faculty and employees union found themselves in a legal battle following a strike staged by the Union. The central question revolved around whether the strike, initiated a day before the completion of the mandatory cooling-off period, was legal, especially considering the Union’s claim of a lockout by the college. This case highlights the delicate balance between adhering to procedural requirements in labor disputes and addressing substantive issues of unfair labor practices.

The case began with the Union filing a notice of strike with the National Conciliation and Mediation Board (NCMB) due to alleged violations of their collective bargaining agreement (CBA). Following unsuccessful conciliation proceedings, the Union threatened to strike. The Department of Labor and Employment (DOLE) then certified the dispute to the National Labor Relations Commission (NLRC) for compulsory arbitration. A second notice of strike was filed by the Union, which led the college to file a motion to strike out the notice and refer the dispute to voluntary arbitration.

The Union asserted that while waiting for the cooling-off period to expire, its members reported for duty. However, on August 9, 2010, they were allegedly denied entry to the school premises, prompting them to stage a strike in protest. The college countered with a petition to declare the strike illegal, leading DOLE to assume jurisdiction and order the strikers to return to work and the school to resume operations. The Labor Arbiter (LA) initially dismissed the college’s petition, finding substantial compliance with strike requirements, but the NLRC reversed this decision, declaring the strike illegal due to non-compliance with procedural requisites. This reversal led the Union to seek relief from the Court of Appeals (CA) through a petition for certiorari.

The Court of Appeals dismissed the petition due to several procedural deficiencies, including deficiencies in docket fees, failure to append an affidavit of service, and improper verification of the petition. The CA emphasized that a pleading lacking proper verification is treated as an unsigned pleading with no legal effect. The Union’s motion for reconsideration was also denied, with the CA stating that the explanations for the procedural lapses were insufficient. The Union then elevated the case to the Supreme Court, arguing that the CA erred in prioritizing technicalities over substantial justice. They contended that the NLRC gravely abused its discretion in declaring the strike illegal and depriving union officers of their employment status. The Union questioned the evidence, specifically the video footage, relied upon by the NLRC, citing concerns about its authenticity and reliability.

The Supreme Court addressed the procedural issues raised by the CA and the college. The Court emphasized that rules of procedure are meant to facilitate justice, not to hinder it. Strict application of these rules should be avoided when it leads to technicalities that frustrate substantial justice. Citing Jaworski v. PAGCOR, the Court reiterated that procedural rules are not inflexible tools designed to hinder or delay, but rather to facilitate and promote the administration of justice. The Court also noted that the right to appeal should not be lightly disregarded, especially when the appeal is meritorious and serves the interest of substantial justice, referencing Pacific Asia Overseas Shipping Corporation v. NLRC, et al.

The Court then delved into the merits of the case, particularly the declaration of the strike a day before the completion of the cooling-off and strike vote periods. The Union argued that this action was a reaction to the college locking out its officers and members. The Court found the sworn statements of the Union officers and members credible, particularly those detailing their denial of entry to the school premises on August 9, 2010. The Court highlighted the testimonies of Engr. Teodomila Mascardo, Engr. Conchita Bagaslao, Ms. Mary Jean Enriquez, and Mr. Cirilo Fallar, who stated that they were prevented from entering the school despite having classes to teach. The Court noted that the NLRC’s rejection of these affidavits as self-serving was unfounded, especially since the college could have presented testimonies from the security guards to counter the Union’s claims.

In contrast, the Court criticized the NLRC for readily admitting the video footage of the strike area, which the college offered only on appeal, more than a year after it was supposedly taken. The Court questioned the authenticity and credibility of this footage, noting the delay in its submission and the potential for manipulation. The Court found the college’s explanation for the delay unconvincing, stating that the inordinate delay raised doubts about the footage’s reliability. Addressing the doubts surrounding the evidence, the Court invoked Article 4 of the Labor Code, which mandates that all doubts in the implementation and interpretation of the Code be resolved in favor of labor. The Court also cited Peñaflor v. Outdoor Clothing Manufacturing Corporation, reiterating that this principle extends to doubts in the evidence presented by the employer and the employee.

The Supreme Court ultimately sided with the Union, emphasizing the importance of protecting workers’ rights and ensuring that labor disputes are resolved fairly. The Court found that the CA erred in dismissing the Union’s petition based solely on technical grounds and in ignoring the NLRC’s grave abuse of discretion. The Supreme Court stated:

Had the CA also looked into the merits of the case, it could have found that the Union’s certiorari petition was not without basis, as we shall discuss below. The case calls for a resolution on the merits. And, although the Court is not a trier of facts, we deem it proper not to remand the case to the CA anymore and to resolve the appeal ourselves, without further delay.

This approach contrasts with the NLRC’s decision, which the Court found to be excessively deferential to the employer’s evidence and dismissive of the employees’ testimonies. The Court emphasized the need for a balanced and fair assessment of evidence in labor disputes, ensuring that the rights of workers are not undermined by procedural technicalities or biased evaluations.

Building on this principle, the Supreme Court’s decision reinforces the idea that labor laws are designed to protect the vulnerable party, which is often the employee. This protection extends to ensuring that doubts in evidence are resolved in favor of labor and that procedural rules do not become instruments of injustice. The Court’s ruling serves as a reminder that while adherence to procedural rules is important, it should not come at the expense of substantive justice and the protection of workers’ rights.

By prioritizing the merits of the case and addressing the substantive issues of the lockout and the reliability of evidence, the Court upheld the principles of fairness and equity in labor relations. This decision underscores the judiciary’s role in safeguarding the rights of workers and ensuring that their voices are heard in disputes with employers. It also highlights the importance of a thorough and impartial evaluation of evidence, especially in cases where the rights and livelihoods of employees are at stake.

This case also has implications for future labor disputes involving strikes and lockouts. It emphasizes the need for employers to act in good faith and to avoid actions that could provoke premature strike actions. It also serves as a guide for labor tribunals and courts in evaluating the legality of strikes, reminding them to consider the context and circumstances surrounding the strike, including any alleged unfair labor practices by the employer. The decision in PMI-Faculty and Employees Union v. PMI Colleges Bohol thus stands as a significant affirmation of workers’ rights and the pursuit of substantial justice in labor law.

FAQs

What was the key issue in this case?	The key issue was whether the strike staged by the Union was legal, considering it was initiated a day before the completion of the mandatory cooling-off period, and whether the alleged lockout by the college justified the premature strike.
Why did the Court of Appeals initially dismiss the Union’s petition?	The Court of Appeals dismissed the petition due to several procedural deficiencies, including deficiencies in docket fees, failure to append an affidavit of service, and improper verification of the petition.
What was the Union’s main argument for staging the strike a day early?	The Union argued that it was forced to stage the strike a day early because the college had locked out its officers and members, denying them entry to the school premises.
What evidence did the college present to counter the Union’s claim of a lockout?	The college presented video footage of the strike area, arguing that it showed that the school did not lock out the Union members and officers.
Why did the Supreme Court question the video footage presented by the college?	The Supreme Court questioned the video footage because it was submitted on appeal, more than a year after it was taken, raising concerns about its authenticity and reliability.
What is the significance of Article 4 of the Labor Code in this case?	Article 4 of the Labor Code states that all doubts in the implementation and interpretation of the Code should be resolved in favor of labor, which the Court invoked in resolving doubts about the evidence.
What was the final ruling of the Supreme Court in this case?	The Supreme Court ruled in favor of the Union, finding that the strike was justified due to the college’s lockout of union members, and emphasized that procedural rules should not overshadow the pursuit of substantial justice.
What is the practical implication of this ruling for labor disputes?	The ruling underscores the importance of protecting workers’ rights to organize and protest unfair labor practices, and serves as a reminder that the strict application of procedural rules should not hinder the fair resolution of labor disputes.

In conclusion, the Supreme Court’s decision in PMI-Faculty and Employees Union v. PMI Colleges Bohol reinforces the importance of balancing procedural compliance with the need to protect workers’ rights and ensure substantial justice in labor disputes. The decision underscores the principle that labor laws are designed to protect the vulnerable party and that doubts in evidence should be resolved in favor of labor.

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: PMI-FACULTY AND EMPLOYEES UNION VS. PMI COLLEGES BOHOL, G.R. No. 211526, June 29, 2016