Philippine Movie Pictures Workers’ Association vs Premiere Productions, Inc.

G.R. No. L-5621 – 92 Phil. 843 – Labor Law – Labor Standards – Police Power – Employment as a Property Right 

In October 1951, Premiere Productions, Inc. (PPI) filed a petition with the Court of Industrial relations (CIR) seeking authority to lay-off 44 workers on the ground of financial losses. The union therein (Philippine Movie Pictures Workers’ Association) opposed the petition as it averred that PPI is merely retaliating against employees who joined a previous strike.

Judge Arsenio Roldan of the CIR then conducted an ocular inspection. The inspection was attended by counsels for both parties. The judge inspected some records and interrogated some witnesses. The counsels for both parties were granted opportunities to cross examine in said ocular inspection. Thereafter, Judge Roldan granted PPI the authority to lay-off the 44 workers.

ISSUE: Whether or not an ocular inspection may be the basis, without receiving full evidence, of determining the cause or motive of laying off employees.

HELD: No. An ocular inspection does not satisfy the procedural requirement. The petition for lay-off was predicated on the lack of work and of the further fact that the company was incurring financial losses – these allegations cannot be proven simply by an ocular inspection. The parties, especially the workers in this case, should not be deprived of their opportunity to present evidence they may deem necessary to establish their case in the main trial. Here, the main trial is absent because all that was conducted was an ocular inspection – such is tantamount to a deprivation of their right to be heard. It is recognized that one’s employment, profession, or trade, or calling, is a property right and the wrongful interference therewith is an actionable wrong. Therefore, the dismissal of the 44 workers without opportunity to be heard is a violation of their property right.

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