G.R. No. 150896 ; August 28, 2008
PUREFOODS CORPORATION, petitioner, vs. NAGKAKAISANG SAMAHANG MANGGAGAWA NG PUREFOODS RANK-AND-FILE, ST. THOMAS FREE WORKERS UNION, PUREFOODS GRANDPARENT FARM WORKERS UNION and PUREFOODS UNIFIED LABOR ORGANIZATION, respondents.

FACTS

Three labor unions, affiliates of the respondent federation Purefoods Unified Labor Organization (PULO), sought to renegotiate their collective bargaining agreements with petitioner Purefoods Corporation. The company refused to recognize PULO’s participation in the negotiations, leading to a deadlock. Subsequently, Purefoods concluded a new CBA with a different union at its Malvar farm. Days later, it facilitated the transfer of poultry stock from its Sto. Tomas farm, where the St. Thomas Free Workers Union (STFWU) was the bargaining agent, to the Malvar farm. The regular rank-and-file workers of the Sto. Tomas farm, all STFWU members, were then refused entry and 22 were terminated, while non-union supervisors and electrical workers were retained. The labor unions filed a complaint for unfair labor practice and illegal dismissal. The Labor Arbiter dismissed the complaint, but the National Labor Relations Commission (NLRC) reversed the decision, finding ULP and ordering reinstatement with backwages. Purefoods filed a petition for certiorari with the Court of Appeals, which dismissed it outright due to a defective verification and certification of non-forum shopping, as the corporate officer who signed it failed to attach proof of authority.

ISSUE

The primary issue is whether the Court of Appeals correctly dismissed Purefoods’ petition for certiorari on a procedural technicality. The substantive issue, which the Supreme Court ultimately addresses, is whether Purefoods committed unfair labor practice and illegally dismissed the STFWU members.

RULING

The Supreme Court reversed the Court of Appeals’ dismissal and ruled on the merits. On procedure, the Court held that while the verification was defective, procedural rules may be relaxed in the interest of substantial justice, especially in labor cases which involve the constitutional rights of workers. The defect was not fatal as the petition itself was verified, and the corporation’s senior vice-president, by the nature of his position, had the authority to act for the company. On the merits, the Court affirmed the NLRC’s finding of unfair labor practice and illegal dismissal. The company’s refusal to negotiate due to the unions’ affiliation with PULO constituted undue interference with the right to self-organization, as PULO was a legitimate federation recognized by the Bureau of Labor Relations. The closure of the Sto. Tomas farm and the dismissal of union members immediately after concluding a CBA with a rival union at another farm evidenced bad faith and union busting. The selective termination of all union rank-and-file members while retaining non-union personnel, coupled with the resumption of operations under a new lease, proved the closure was not due to genuine financial losses but was a pretext to rid the company of union members. This constituted illegal dismissal and ULP under Article 248 of the Labor Code. The Court reinstated the NLRC decision ordering reinstatement with full backwages.