FEATI UNIVERSITY FACULTY CLUB (PAFLU), PETITIONER, VS. FEATI UNIVERSITY AND COURT OF INDUSTRIAL RELATIONS, RESPONDENTS.

Feati University versus Feati University Faculty Club

The Case

This is a labor case between the Feati University Faculty Club, a registered labor union of professors and instructors, as petitioner, and Feati University together with the Court of Industrial Relations, as respondents. The union asked the Supreme Court to reverse a decision of the industrial court that would have negated and nullified that court's own earlier return-to-work order and its award of backwages to the faculty members. The case matters because it shows how a final judgment becomes res judicata — the doctrine that a matter finally adjudged may no longer be reopened — and because it teaches that a strike does not sever the employer-employee relationship, so that strikers keep their right to return to work and to be paid accrued backwages when the employer refuses in bad faith to readmit them.

Procedural History

The dispute began with a strike declared in February 1963 by the faculty club against the university on the ground of unfair labor practice. The President certified the labor dispute to the Court of Industrial Relations for compulsory arbitration. The industrial court issued a return-to-work order in March 1963 and an implementing order in April 1963, and later issued an order for the arrest of university officers for indirect contempt. The university challenged these orders before the Supreme Court in three cases, which were jointly decided in December 1966. The Supreme Court upheld the industrial court on all disputed issues, and that decision became final and executory with entry of judgment in August 1968.

After entry of judgment, the faculty club filed motions to execute the return-to-work order and to collect accrued back salaries. The industrial court, through Judge Joaquin A. Salvador, issued an order in February 1969 directing execution of the return-to-work order and awarding accrued backwages from July 1963 until actual readmission. The university challenged this later order, and the industrial court issued a decision that would have nullified its own earlier orders. The case then reached the Supreme Court on petition, and the Court reversed the industrial court's later decision.

Facts

In January 1963 the faculty club informed the university president of its organization as a registered labor union and sent twenty-six demands concerning the employment of its members. The university asked for time to study the demands and demanded proof of the union's majority status. The union rejected the request for extension and filed a notice of strike, alleging the university's refusal to bargain collectively. Conciliation failed, and in February 1963 the faculty members declared a strike and established picket lines, disrupting classes.

The President certified the dispute to the Court of Industrial Relations. At a hearing in March 1963, the parties agreed that the strikers would return to work under the status quo arrangement and that the university would readmit them. The industrial court confirmed this agreement in its return-to-work order of March 1963, directing the strikers to return immediately and the university to take them back under the last terms and conditions existing before the dispute. The university did not fully comply, and replacements it had hired refused to yield their posts.

The Supreme Court's 1966 decision upheld the industrial court's jurisdiction, the employee status of the faculty members, the validity of the presidential certification, and the return-to-work order. It held that the striking faculty members had not abandoned their employment but had only ceased from their labor, and that the employment of replacements did not vest in them a permanent right to the positions. When the union later moved to execute the order and collect backwages, the industrial court found the university's persistent refusal to readmit the members to be bad faith and awarded accrued back salaries from July 1963 until actual readmission.

Issues

• Whether or not the industrial court's later decision, which would negate and nullify its earlier return-to-work order and backwage award, is barred by res judicata in view of the final judgments of the Supreme Court.
• Whether or not the industrial court's decision repudiating its earlier orders, as upheld by final judgments, has factual and legal basis.
• Whether or not the faculty club members are entitled to accrued backwages from the date of their right to readmission until actual readmission.

Applicable Provisions

Section 2, paragraph (d) of the Industrial Peace Act, Republic Act Number 875, defines employees and provides:

Any individual whose work has ceased as a consequence of, or in connection with, any current labor dispute or of any unfair labor practice and who has not obtained any other substantially equivalent and regular employment.

This provision is the basis for holding that the striking professors and instructors continued to be employees of the university for purposes of the labor controversy, notwithstanding the termination of their teaching contracts.

Article 1700 of the Civil Code provides:

Labor contracts must yield to the common good and such contracts are subject to the special laws on labor unions, collective bargaining, strikes and similar subjects.

This provision supports the ruling that the return-to-work order did not impair the university's contracts with the replacements, since labor contracts must yield to the common good and to the special labor laws.

Ruling

On the first issue, the Court ruled that the factual findings, conclusions, and orders rendered in the earlier industrial court proceedings, as affirmed by two final judgments of the Supreme Court, are now res judicata and may no longer be reopened, much less set aside by the industrial court. The industrial court's later decision would negate and nullify its own earlier return-to-work order and backwage award, which the Court would not allow.

On the second issue, the Court found that the industrial court's decision repudiating its earlier orders, as upheld by final judgments, was bereft of factual and legal basis. The Court had already settled that the striking faculty members did not abandon their employment; they only ceased from their labor. The employment of replacements was a temporary expedient that did not vest in them a permanent right to the positions, and the university had the power to terminate those replacements to comply with the return-to-work order.

On the third issue, the Court upheld the award of accrued backwages. The industrial court had found the university's persistent refusal to take back the faculty members, despite its return-to-work agreement and the finality of the 1966 decision, to be bad faith. The members were therefore entitled to accrued salaries from the date of their right to readmission until actual readmission. The Court remanded the case to the industrial court to fix and resolve with deliberate dispatch the terms and conditions of employment involved in the labor dispute certified by the President for compulsory arbitration in the national interest.

Doctrine

A final judgment is res judicata and may no longer be reopened, much less set aside, by the court that rendered it. When the Supreme Court has affirmed the orders of an industrial court, those orders become final and executory, and the industrial court cannot later repudiate them.

A strike does not sever the employer-employee relationship. Under Section 2, paragraph (d) of the Industrial Peace Act, an individual whose work has ceased as a consequence of, or in connection with, a current labor dispute remains an employee, so striking faculty members keep their right to return to their positions. The employment of replacements is a temporary expedient that does not vest in them a permanent right to the positions.

Labor contracts must yield to the common good and are subject to the special laws on labor unions, collective bargaining, strikes, and similar subjects, as Article 1700 of the Civil Code provides. Thus, a return-to-work order does not impair the employer's contracts with replacements.

An employer's persistent refusal to readmit strikers in bad faith, despite a return-to-work agreement and a final judgment, entitles the strikers to accrued backwages from the date of their right to readmission until actual readmission.

Disposition

The Supreme Court reversed the industrial court's decision under review, upheld the earlier return-to-work order and backwage award, and remanded the case to the industrial court to fix and resolve with deliberate dispatch the terms and conditions of employment in the certified labor dispute.

Remember This

The single line worth memorizing is that a strike does not sever the employer-employee relationship, and a final judgment is res judicata that may no longer be reopened. Examiners like to use this case on the employee status of strikers, the temporary nature of replacements, and the award of backwages for bad-faith refusal to readmit.