Facts:

During the renegotiation of the respondent unions Collective Bargaining Agreement with the petitioner, Eleonor Ambas emerged as
the newly elected President of the union. Ambas wanted to continue the renegotiation of the CBA but petitioner, through Fr. Edwin
ao, claimed that the CBA was already prepared for signing by the parties. !owever, the union members re"ected the said CBA.
#hereafter, petitioner accused the union officers of bargaining in bad faith before the $%C. #he abor Arbiter decided in favor of
the petitioner. #his decision was reversed on appeal with the $%C.
#he parties later agreed to disregard the unsigned CBA and to start negotiation on new five&year CBA. During the pendency of
approval of proposals, Ambas was informed that her wor' schedule was being changed. Ambas protested and re(uested
management to submit the issue to a grievance machinery under the old CBA.
After the petitioner)s inaction on the CBA, the union filed a notice to stri'e. After meeting with the $C*B to discuss the ground
rules for renegotiation, Ambas received a letter dismissing her for alleged insubordination. #he petitioner then ceased negotiations
when it received news that another labor organi+ation had filed a petition for certification.
#he union finally struc', but the ,ecretary of abor and Employment ordered them to return to wor' and for petitioner to accept
them bac'. #he ,ecretary of abor and Employment later rendered "udgement that the petitioner had been guilty of unfair labor
practice. #he Court of Appeals affirmed the findings of the former.
Issue(s):
-. .hether petitioner is guilty of unfair labor practice by refusing to bargain with the union when it unilaterally suspended
the ongoing negotiations for a new CBA/ and
0. .hether the termination of the union president amounts to an interference of the employees) right to self&organi+ation.
Held:
#he ,upreme Court found the petition unmeritorious.
-. #he petitioner)s failure to act upon the submitted CBA proposal within the ten&day period e1emplified in Article 023 of the
abor Code is a clear violation of the governing procedure of collective bargaining. As the Court has held in 4io' oy vs.
$%C, the company)s refusal to ma'e counter&proposal to the union)s proposed CBA is an indication of bad
faith. *oreover, the succeeding events are obvious signs that the petitioner had merely been employing delaying tactics to
the passage of the proposed CBA. *oreover, in order to allow the employer to validly suspend the bargaining process,
there must be a valid petition for certification election raising a legitimate representation issue. !ence, the mere filing of a
petition for certification election does not ipso facto "ustify the suspension of negotiation by the employer.
0. #he factual bac'drop of the termination of Ambas led the Court to no other conclusion that she was dismissed in order to
strip the union of a leader who would fight for the right of her co&wor'ers in the bargaining table. .hile the Court
recogni+es the right of the employer to terminate the services of an employee for a "ust or authori+ed cause, nevertheless,
the dismissal of employees must be made within the parameters of aw and pursuant to the tenets of e(uity and fair
play. Even assuming arguendo that Ambas was guilty of insubordination, such disobedience was not a valid ground to
terminate her employment. .hen the e1ercise of the management to discipline its employees tends to interfere with the
employees) right to self&organi+ation, it amounts to union&busting and is therefore a prohibited act.