Scoty’s Department Store v.

Micaller (1956)

Doctrine: To allow the Court of Industrial Relations to impose fines would be contrary to the
constitutional guarantees of no one shall answer for a criminal offense without due process
[because] CIR hearings would not follow the rules of evidence and other technical rules.

Summary: Nena Micaller was employed in Scoty’s Department store as a salesgirl. Micaller
organized a labor union among the stores of the employees and subsequently a letter containing
ten demands by the union was sent to the management. As a result Micaller was called and
questioned by management to identify the members of the union, where she then feigned
ignorance of knowledge of the identities of the union’s members. Micaller was questioned
regarding her membership in the union, then made to sign a letter of withdrawal from the
union. Management then questioned employees if they were members of the union. After the
union sent a notice of strike, management hired temporary employees. Micaller was
subsequently for allegedly insulting the owner of the store and for talking to the girls inside the
store during business hours. Micaller then filed a case for illegal dismissal and citing
respondents guilty of unfair labor practices. The CIR ruled in favor of Micaller, ruling that Nena
Micaller was dismissed because of her membership in the National Labor Union and her union
activities; that petitioners have committed unfair labor practice; and that petitioners can be
legally punished by a fine of P100.

Issue: W/N The CIR had jurisdiction to fine the management of Scoty’s Department Store?

Ruling: NO.
The Court held that despite Scoty’s claims there was no clear evidence of unfair labor practice,
the evidence clearly showed Scoty’s had committed unfair labor practices. However, the Court
held that the CIR was not vested with the proper authority to impose fines on parties guilty of
committing unfair labor practices. The Court in interpreting Sec. 25’s wording of “under the
discretion of the court” posited that what was referred to were regular courts. The Court
reasoned that to allow the CIR to impose fines would be contrary to the constitutional
guarantees of no one shall answer for a criminal offense without due process. This was due to
the fact CIR hearings would not follow the rules of evidence and other technical rules. Such a
measure would undermine this constitutional guarantee. The Court then compared the
jurisdiction of the CIR to that of the Court of Agrarian reform. After interpreting the laws and
going through the law’s history it was seen that such courts are not vested with the jurisdiction
to impose fines.