Toyota vs NLRC

The validity of the Toyota Motor Phils’ strikes is at issue in this case. Corp. the explanation
provided by the Workers Association (Union) for the termination of union leaders and members.
The Union is an authorized labor union that works on behalf of Toyota Motor Philippines
Corporation’s (Toyota) general workforce.
The Department of Labor and Employment (DOLE) approved the Union’s demand for a
certification election among Toyota workers.
The Union filed a notice of strike after Toyota declined to engage in negotiations.
The Union’s orchestrated strikes led to work stoppages and operational interruptions, resulting in
substantial losses for Toyota.
227 Union officers and members were fired by Toyota for taking part in the unlawful strikes.
Issue:
Whether or not the strikes staged by the Union were legal or illegal.
Whether or not the dismissal of the Union officers and members was justified.
Ruling:
The strikes staged by the Union were declared illegal.
The dismissal of the Union officers and members was upheld.
Ratio:
A strike is considered illegal if it fails to comply with the procedural requirements under the
Labor Code.
Union officers and members can be dismissed if they knowingly participate in an illegal strike or
commit illegal acts during a strike.
Union officials have a duty to guide their members to respect the law, and if they urge the
members to violate the law, their dismissal is a just penalty.
Ordinary union members who merely participated in the illegal strikes without committing any
illegal acts cannot be terminated from employment.
Mere membership in a labor union does not automatically make a member liable for acts done on
behalf of the union.
“Illegal acts” during a strike may include violations of labor or criminal laws, commission of
crimes and other unlawful acts, and violation of orders or injunctions issued by the Department
of Labor and Employment (DOLE) or National Labor Relations Commission (NLRC).
Separation pay should not be granted to union officials and members who were validly
terminated for serious misconduct.
Social justice should not be used to condone wrongdoing or reward those who have proved they
are not worthy of protection.
Employers and employees should view each other as partners and seek amicable means of
resolving disputes rather than resorting to strikes and lockouts.