Labor Law

Narcisa De Leon vs National Labor Union

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G.R. No. L-7586 – 100 Phil. 789 – Labor Law – Labor Relations – Labor Rights – Picketing

Political Law – Constitutional Law – Freedom of Speech 

Narcisa De Leon was the owner of a parcel of land where the Dalisay Theater stands. She does not own the building.

In 1951 however, De Leon was able to buy the Dalisay Theater. The previous owner, the Filipino Theatrical Enterprises, Inc., then notified its theater employees (Alejandro Bartolome et al) that the theater is already sold, hence all employee services will be terminated on August 14, 1951.

On August 15, 1951, when the building was turned over to De Leon, she began demolishing it. Eventually, a new Dalisay Theater was built. It was opened in January 1952 with a new set of employees.

Meanwhile, the National Labor Union, assisted the former employees (Bartolome et al) and organized a picket in front of the Dalisay Theater where they walked to and fro on the side walk fronting the lobby of the theater and displaying placards which bore the slogans: “Do not patronize the Dalisay Theater,” “Dalisay Theater is unfair to labor.”, etc.

As a result, the Dalisay Theater incurred losses. De Leon then filed a case of injunction against the picketers to enjoin them from rallying in front of her theater. The trial court denied De Leon’s complaint.

ISSUE: Whether or not the trial court’s ruling is correct.

HELD: Yes. It is true that there existed no employer-employee relationship between De Leon and the picketing ex-employees but the employees right to picket is protected by the constitution. Picketing peacefully carried out is not illegal even in the absence of employer-employee relationship for peaceful picketing is a part of freedom of speech guaranteed by the Constitution.

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