**Cromwell Commercial Employees and Laborers Union (PTUC) vs. Court of Industrial Relations and Cromwell Commercial Co., Inc.**
### Facts:
In July 1956, Cromwell Commercial Co. and Cromwell Commercial Employees and Laborers Union (PTUC) signed a collective bargaining agreement (CBA) establishing conditions such as permanent employee status after three months of satisfactory service, the formation of a “Grievance Committee,” salary increases based on financial performance, restoration of salesmen to salary basis, and profit-sharing considerations. Despite a profit of P90,000 at the second quarter’s end of 1956, the company did not grant salary increases except to three non-union members and failed to fully restore salesmen’s salaries and allowances. This led to tensions, highlighted by the company’s refusal to engage in the grievance procedure and the subsequent dismissal of union leaders, promoting a strike and picketing by union members. The company responded by threatening dismissal for participating employees. Efforts at reconciliation failed, and the company’s conditions for resolving the dispute were not acceptable to the union members, leading to the filing of an unfair labor practice case in the Court of Industrial Relations.
### Issues:
1. Whether the Court of Industrial Relations has the authority to order reinstatement and payment of back wages in cases of unfair labor practices.
2. The entitlement of discriminatorily dismissed employees versus striking employees to reinstatement.
3. The entitlement of employees to back wages, distinguishing between those discriminatorily dismissed and those who voluntarily went on strike.
### Court’s Decision:
The Supreme Court upheld the Court of Industrial Relations’ decision, affirming the court’s authority to issue directives for reinstatement and back wages to rectify unfair labor practices. It distinguished between employees dismissed due to discrimination, who were entitled to reinstatement and back wages, and those who voluntarily went on strike, whose entitlements were more limited. Specifically, the Court ruled that striking employees could be reinstated without back wages unless their offer to return was unconditionally refused or met with new, discriminatory conditions by the employer.
### Doctrine:
1. Discriminatorily dismissed employees are entitled to reinstatement and back wages from the date of their unjust dismissal.
2. Voluntary strikers are entitled to reinstatement but not necessarily to back wages unless their unconditional offer to return is met with refusal or discriminatory conditions by the employer.
### Class Notes:
– **Unfair Labor Practices**: Actions by employers or unions that violate workers’ rights or the ability to negotiate employment conditions.
– **Collective Bargaining Agreement (CBA)**: A legal contract between an employer and a union representing the employees, outlining the terms of employment.
– **Discriminatory Dismissal**: Termination based on union activities or other protected characteristics, warranting reinstatement and back wages.
– **Voluntary Strike**: A work stoppage initiated by employees to protest against workplace conditions, not always warranting back wages upon reinstatement if due to employer’s unfair practices.
– **Reinstatement with Back Wages**: A remedial action where unjustly dismissed employees are restored to their positions with compensation for lost wages.
### Historical Background:
This case emphasizes the complexities of labor disputes and the enforcement of collective bargaining agreements within the Philippine legal context during the 1950s. The scenario underscores the challenges in balancing the rights of employees to organize and strike against the employer’s prerogatives, within the legislative framework aimed at promoting industrial peace. The decision reiterates the court’s role in interpreting CBA provisions and mediating between conflicting rights, reflecting the evolving nature of labor law in the Philippines.
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