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GALAXIE STEEL WORKERS UNION v. NLRC

FACTS:

Respondent Galaxie Steel Corporation (Galaxie) closed down its business operations due to significant losses from 1997 to mid-1999. It filed a notice of intended closure with the DOLE and posted the notice on its bulletin board. Petitioners, the Galaxie Steel Workers Union and Galaxie employees, filed a complaint for illegal dismissal, unfair labor practice, and money claims against Galaxie. The Labor Arbiter declared Galaxie's closure as valid but ordered it to pay separation pay and other benefits. The NLRC upheld the Labor Arbiter's decision but reversed the award for certain benefits. The Court of Appeals affirmed the NLRC decision. The issues raised in the petition are unfair labor practice, entitlement to separation pay, and compliance with notice requirement. The Court finds that Galaxie's closure was due to business losses and not anti-union stance. The notice posted on the bulletin board is considered sufficient notice to the employees.

ISSUES:

  1. Whether Galaxie is guilty of unfair labor practice in closing its business operations shortly after petitioner union filed for certification election.

  2. Whether petitioners are entitled to separation pay.

RULING:

  1. The Court found that Galaxie's closure of business operations was due to serious business losses or financial reverses, and not because of any alleged anti-union position. The Court upheld the findings of the Labor Arbiter, NLRC, and the Court of Appeals on this matter.

  2. The Court affirmed the NLRC's decision to reverse the award of separation pay to the petitioners, as the closure of Galaxie's business was due to serious business losses.

PRINCIPLES:

  • The Court is not a trier of facts and accords respect and finality to the findings of fact of the NLRC, as long as they are supported by substantial evidence.

  • Closure of business operations due to serious business losses is a valid ground for termination of employees, and separation pay may not be awarded in such cases.

  • The compliance of a written notice with the notice requirement under Article 283 of the Labor Code was not discussed or ruled upon in this case.