Facts:
The Philippine Blooming Mills Employees Organization (PBMEO) is a legitimate labor union composed of employees from the Philippine Blooming Mills Co., Inc. On March 1, 1969, the PBMEO decided to hold a mass demonstration at Malacañang on March 4, 1969, to protest alleged police abuses. They informed the company about their planned demonstration. However, the company, learning of this protest, warned that any employee participating, especially the organizers, without approved leave, would be dismissed for violating the Collective Bargaining Agreement (CBA). Unfazed, the employees participated in the demonstration, and the company subsequently filed a charge against them. The trial court found PBMEO guilty of bargaining in bad faith and ruled the officers responsible for the protest lost their employment status. PBMEO filed a motion for reconsideration beyond the five-day reglementary period, which the CIR dismissed for being pro forma as it was filed late. Upon receipt of the resolution dismissing their motion, PBMEO filed a petition for relief on the ground of excusable negligence for their failure to comply with the period, which went without resolution. They then filed a notice of appeal with the Supreme Court.
Issues:
1. Whether the right to freedom of speech and assembly can justify the participation of the PBMEO and its officers in a mass demonstration against the police, which resulted in their absence from work and subsequent charge of bargaining in bad faith.
2. Whether the Court of Industrial Relations erred in ruling that PBMEO officers who participated in the protest lose their employment status.
3. Whether the dismissal of the motion for reconsideration for being filed late constitutes a denial of due process.
Court’s Decision:
The Supreme Court set aside the orders of the Court of Industrial Relations. It directed the reinstatement of the PBMEO officers, with back pay from the date of their separation from service until reinstatement, minus one day’s pay and the earnings they may have acquired from other sources during their separation from service. The Court found that the demonstration was an expression of the workers’ constitutional rights to speech, assembly, and to petition the government for redress of grievances. The Court determined that such rights should take precedence over potential loss due to their absence from work for one day. Moreover, the Court held that the rules on the filing and period of appeals from the CIR should not impinge on the exercise of constitutional rights, and a two-day delay in filing a motion for reconsideration does not warrant the denial of due process.
Doctrine:
Constitutional rights, such as freedom of expression and peaceable assembly, take precedence over contractual obligations and procedural technicalities when these rights are exercised in good faith and within legal bounds. Due process is not denied by procedural rules, as long as such rules do not diminish the substantive rights being exercised.
Class Notes:
– The freedoms of speech and assembly are fundamental political rights that ensure the participation of the people, including workers, in the administration of public affairs. They are essential for the promotion of democratic ideals and should be given primacy over mere contractual arrangements, especially in the context of labor relations.
– The no-lockout and no-strike provision in a CBA should not infringe upon the workers’ rights to organize and express collective interests in a manner consistent with the Constitution.
– The five-day period prescribed by the CIR for the filing of a motion for reconsideration is not unjust, nor does a slight delay in such filing necessarily deny due process.
Historical Background:
The case took place during a period in Philippine history when labor unrest was common, and the constitutional rights to freedom of speech and assembly were of critical importance for workers to voice their grievances. The decision in this case reiterates the balance that needs to be struck between maintaining industrial peace and respecting the constitutional rights of workers.
Leave a Reply