Galaxie Steel Workers Union v.

NLRC, Galaxie Steel Corporation

G.R. No. 165757 – October 17, 2006
J.Carpio-Morales

Topic: Unfair Labor Practice Acts

Doctrine: Unfair labor practice refers to acts that violate the workers’ right to organize, and are defined in
Articles 248 to 260 of the Labor Code. The prohibited acts relate to the workers’ right to self-organization, and
the observance of CBA without which relation, the acts, no matter how unfair, are not deemed unfair labor
practices

Petitioner: Galaxie Steel Workers Union

Respondent: NLRC, Galaxie Steel, Ricardo Cheng

Case Summary: Galaxie Steel (GS) filed a written notice with the DOLE informing the latter of its
intended closer and consequent termination of employees effective August 31, 1999. On September 8, 1999:
Members of the GSWU filed a complaint for illegal dismissal, unfair labor practice, and money claims.

Issue: W/N closure was proper and not due to unfair labor practices – YES

Held: The SC is not a trier of facts; the LA, NLRC, and the CA were all unanimous in ruling that Galaxie’s
closure or cessation of business was due to serious business losses or financial reverses, and not because of
any alleged “anti-union” position. Galaxie’s documentary evidence shows that it had been experiencing
serious financial losses at the time it closed business operations. On the other hand, petitioners failed to
present concrete evidence supporting their claim of unfair labor practice. Unfair labor practice refers to acts
that violate the workers’ right to organize, and are defined in Articles 248 to 260 of the Labor Code. The
prohibited acts relate to the workers’ right to self-organization, and the observance of CBA without which
relation, the acts, no matter how unfair, are not deemed unfair labor practices

Facts:
 July 30, 1999: Galaxie Steel (GS) filed a written notice with the DOLE informing the latter of its
intended closer and consequent termination of employees effective August 31, 1999
 September 8, 1999: Members of the GSWU filed a complaint for illegal dismissal, unfair labor
practice, and money claims
 LA stated that there was a valid closure, but that GS should still pay GSWU employees separation pay
 NLRC – affirmed valid closure, but reversed payment of separation pay due to closure by business
losses
 CA – Affirmed

Issues + Held:
1. W/N closure was proper and not due to unfair labor practices – YES
 The SC is not a trier of facts; the LA, NLRC, and the CA were all unanimous in ruling that Galaxie’s
closure or cessation of business was due to serious business losses or financial reverses, and not
because of any alleged “anti-union” position
o Galaxie’s documentary evidence shows that it had been experiencing serious financial losses
at the time it closed business operations
 On the other hand, petitioners failed to present concrete evidence supporting their
claim of unfair labor practice.
 Unfair labor practice refers to acts that violate the workers’ right to organize, and are
defined in Articles 248 to 260 of the Labor Code
  The prohibited acts relate to the workers’ right to self-organization, and the
observance of CBA without which relation, the acts, no matter how unfair,
are not deemed unfair labor practices
 Art. 283 governs the grant of separation benefits “in case of closures or cessation of operation” of
business establishments “NOT due to serious business losses or financial reverses…” Where the
closure is due to serious business losses, the LC does not impose any obligation upon the employer to
pay separation benefits.

Ruling: Decision and Resolution appealed from is AFFIRMED with MODIFICATION.