MAYA FARMS EMPLOYEES ORGANIZATION, MAYA REALTY AND LIVESTOCK SUPERVISORY UNION, MAYA FARMS EMPLOYEES ASSOCIATION, and MAYA FARMS, INC. SUPERVISORY UNION, vs. NATIONAL LABOR RELATIONS COMMISSION, MAYA REALTY & LIVESTOCK, INC., MAYA FARMS, INC., and LIBERTY FLOUR MILLS, INC..
- G.R. Number: G.R. No. 106256
- Promulgated: 1994-12-28
- Ponente: Kapunan, J.
Doctrine
Labor laws discourage court interference with employer management prerogatives; employer action will be upheld if in good faith and not intended to defeat employee rights.
On certiorari review the Court will examine NLRC factual findings only to determine grave abuse of discretion amounting to lack or excess of jurisdiction.
Facts
Petition seeks to set aside NLRC decision that upheld legality of separation of sixty-six employees who are union members and dismissed charges of CBA violation and unfair labor practice.
Private respondents are Maya Farms, Inc. and Maya Realty and Livestock Corporation, part of the Liberty Mills group operating a meat‑processing plant.
NLRC confirmed separations, ordered companies to comply with their notice of termination dated 17 January 1992 and pay separation benefits to remaining employees as listed.
Disputed factual points included retention of three of eight driver positions under seniority and alleged nonobservance of LIFO in two assistant superintendent positions; 30‑day notice was found given on 17 January 1992.
Issues
Whether the NLRC gravely abused its discretion in upholding the separations and dismissing the unions' charges of CBA violation and unfair labor practice.
Whether management failed to observe the LIFO (last‑in, first‑out) rule in retaining a later‑hired assistant superintendent over an earlier‑hired one.
Whether the employers substituted separation pay for the 30‑day notice required by law.
Ruling
The petition was dismissed; the Court found no grave abuse of discretion amounting to lack or excess of jurisdiction by the NLRC and confirmed the legality of the separations, ordering compliance with the notice and payment of separation benefits.
Keywords
G.R. No. 106256, National Labor Relations Commission (NLRC), collective bargaining agreement (CBA), unfair labor practice, early retirement program, special redundancy program, redundancy, management prerogative, Last-In-First-Out (LIFO) Rule (CBA Section 2, Article III), security of tenure, Article 283 of the Labor Code, grave abuse of discretion, compulsory arbitration, National Conciliation and Mediation Board (NCMB), separation benefits, jurisdiction, employees, termination, sixty six, public