The Supreme Court denied the Petition for Review on Certiorari filed by Central Azucarera De San Antonio, Inc., affirming with modification the rulings of the Court of Appeals. The Court denied Central Azucarera's counterclaim for actual, moral, and exemplary damages, as well as attorney's fees, against CASA Sugar Mill Workers Union-FFW.
The Case
CASA Sugar Mill Workers Union-FFW (CASA) is the sole bargaining representative of all the rank-and-file employees of Central Azucarera De San Antonio, Inc. (Central Azucarera), a domestic corporation engaged in the business of milling and trading sugar. The late Antonio Steven Chan was the former president of Central Azucarera.
On August 16, 2017, CASA filed a complaint for unfair labor practices against Central Azucarera and Chan because of their alleged bad faith in bargaining, refusal to negotiate, and discrimination in the grant of milling bonus. According to CASA, during a prolonged negotiation for a Collective Bargaining Agreement (CBA), a deadlock ensued, prompting CASA to request the intervention of the National Conciliation and Mediation Board (NCMB) of the Department of Labor and Employment (DOLE).
After fruitless negotiations, CASA conducted a strike vote, wherein 95% of its members voted to go on strike. Its members staged a strike on March 29, 2017, which ended on April 12, 2017, after Central Azucarera agreed to accept back the workers who went on strike. However, after returning to their posts, the officers and certain members of CASA received a Notice to Explain, and Central Azucarera later dismissed them.
For its part, Central Azucarera said that during the second week of the strike, on April 5, 2017, the officers and members of CASA, using motorcycles, amakan, and palay, barricaded the road junction leading to Gate 1 of the sugar central, obstructing the free entry and exit of persons. Central Azucarera filed a petition for injunction against CASA before the National Labor Relations Commission (NLRC) and temporarily withheld half of the bonus of employees involved in the illegal strike who had pending disciplinary cases.
The Labor Arbiter, in its Decision dated April 10, 2018, dismissed CASA's complaint for lack of cause of action. The CA agreed with the NLRC that the labor tribunals do not have jurisdiction over Central Azucarera's counterclaim for damages and attorney's fees, but also held that Central Azucarera is not entitled to its counterclaim.
The Issue
Whether Central Azucarera is entitled to its counterclaim for actual, moral, and exemplary damages, as well as attorney's fees, for losses resulting from illegal acts committed during the strike.
The Ruling
The Court denied the petition. It ruled that Central Azucarera's claim for actual, moral, and exemplary damages, as well as attorney's fees, cannot be granted where the record fails to clearly establish the participation of specific union officers or members in the commission of illegal acts or the presence of bad faith in their conduct.
The dispositive portion states: "ACCORDINGLY, the Petition for Review on Certiorari filed by Central Azucarera De San Antonio, Inc. is DENIED. The Decision dated May 28, 2021, and the Resolution dated November 18, 2021, of the Court of Appeals in CA-G.R. SP No. 12380 are AFFIRMED with MODIFICATION. The counterclaim of Central Azucarera De San Antonio, Inc. against CASA Sugar Mill Workers Union-FFW for actual, moral, and exemplary damages, as well as attorney's fees, is denied for failure to establish by substantial evidence the individual participation of specific union officers or members and the presence of bad faith in the commission of illegal acts during the strike."
By the Numbers
- G.R. No. 259683
- Complaint filed: August 16, 2017
- Strike staged: March 29, 2017 to April 12, 2017
- Strike vote: 95% of members voted to go on strike
- Barricade: April 5, 2017
- Damages prayed for by CASA: PHP 1,000,000.00
- Labor Arbiter Decision: April 10, 2018
- CA Decision: May 28, 2021; CA Resolution: November 18, 2021
The Court's Reasoning
The Court emphasized that social justice and the protection of workers are firmly enshrined in the Constitution, citing Article II, Section 18 and Article XIII, Section 3. It noted that workers generally stand on unequal footing with employers, and labor is regarded as a distinct class deserving constitutional protection.
The Court laid down principles governing the award of damages to employers for losses resulting from illegal acts committed during a strike. First, an employer must prove with substantial evidence that union officers or members committed illegal acts during the strike, that these acts were carried out in bad faith, and that the employer suffered harm as a direct result. Second, liability rests solely on the union members or officers who personally engaged in illegal acts, not on the union as a whole. Third, in assessing a fair award, tribunals must ensure it accurately reflects the harm suffered, though it may be adjusted downward in the interest of social justice.
The Court also adopted the doctrine articulated by Associate Justice Amy C. Lazaro-Javier that damages should be confined to exceptional circumstances, where the losses go beyond the ordinary and foreseeable consequences of a strike. Applying these principles, the Court held that the award of damages under Articles 19 and 20 of the Civil Code, as well as the Labor Code, requires substantial evidence demonstrating both the unlawful acts and the bad faith of the individuals directly responsible. Without such proof, liability cannot be imposed.
Source: Supreme Court Decision in G.R. No. 259683 (Central Azucarera De San Antonio, Inc. v. CASA Sugar Mill Workers Union-FFW).
This report summarizes a public Supreme Court decision and is not legal advice.