Case Digest (G.R. No. 112955)
Facts:
The case involves the Aboitiz Shipping Employees Association (petitioner) against the Honorable Undersecretary of Labor and Employment Cresenciano Trajano and Director Bernardino Julve (respondents). The events leading to the case began in 1987 when the petitioner filed a complaint against Aboitiz Shipping Corporation (ASC) for non-compliance with the mandated minimum wage as stipulated in various Presidential Decrees (P.D. Nos. 1713 and 1751) and Wage Orders. The complaint was lodged before the National Capital Region (NCR) Regional Office of the Department of Labor and Employment (DOLE). Following the receipt of the complaint, an inspection of ASC's premises and employment records was conducted by the NCR Regional Director. After evaluating the evidence presented by both parties, the Regional Director issued an order requiring ASC to pay the complainants a total of P1,350,828.00, which represented the underpayment of a daily allowance of P2.00 per day from February 16, ...
Case Digest (G.R. No. 112955)
Facts:
- In 1987, the petitioner, Aboitiz Shipping Employees Association, filed a complaint for non-compliance with the mandated minimum wage.
- The complaint cited violations of Presidential Decrees Nos. 1713, 1751, and Wage Orders Nos. 1, 2, 3, 4, 5, and 6 against Aboitiz Shipping Corporation (ASC).
Background of the Case
- Upon receipt of the complaint, the National Capital Region (NCR) Regional Office of the Department of Labor and Employment (DOLE) conducted an inspection of ASC’s premises and employment records under the supervision of NCR Regional Director, Hon. Luna C. Piezas.
- Based on the evaluation of the evidence, the Regional Director issued an order awarding the petitioner a total monetary relief of ₱1,350,828.00.
- The award represented the underpayment of daily allowances amounting to ₱2.00 per day for the period from February 16, 1982, to February 15, 1985.
- In addition, an order was issued directing ASC to pay each employee the deficiency in allowance of ₱2.00 per day from February 16, 1985, onward until full compliance was achieved.
Investigation and Initial Order
- ASC interposed an appeal, which was dismissed by the Secretary of Labor.
- A motion for reconsideration by ASC was likewise denied.
- On a petition for certiorari, the decision of the Regional Director was affirmed with a modification—specifically, the exclusion of Mr. Elizardo Manuel from the list of complainants entitled to the monetary award.
- ASC filed a motion for reconsideration raising both jurisdictional and factual issues concerning the award, which was denied in a Resolution promulgated on July 25, 1991.
ASC’s Appeals and Subsequent Proceedings
- On August 6, 1991, the petitioner filed a motion for the issuance of an alias writ of execution before the Regional Director, which was granted.
- ASC appealed the writ of execution, prompting the public respondent, Secretary of Labor, to set aside the order of execution.
- The Secretary created a Special Committee tasked with computing the exact amount of ASC’s liability.
- The Committee reevaluated the case records and ASC’s newly adduced evidence, including company payrolls.
- Their findings led to a Report reducing the original monetary award from ₱1,350,828.00 to ₱209,183.42, which was subsequently approved by the public respondent.
- The petitioner filed a motion for reconsideration, arguing that an order of execution is not appealable and that the public respondent lacked jurisdiction to reduce an already final and executory award.
- The motion for reconsideration was denied, leading to the present petition.
Later Developments and the Special Committee Intervention
- The petitioner contended that the public respondent committed grave abuse of discretion by modifying the final and executory decision of the Regional Director.
- The petitioner insisted that the reduction of the award, which was based on evidence already accessible during the hearing on the merits, was impermissible as the judgment was final and executory.
Petition and Relief Sought
Issue:
- Whether an order of execution, once final and executory, is appealable or subject to modification by the public respondent.
- Whether public respondent had jurisdiction to reduce the monetary award previously set by the Regional Director.
Jurisdictional and Procedural Concerns
- Whether the new evidence adduced by ASC during the re-evaluation process could justify the reduction of the award.
- Whether the Special Committee’s findings, which formed the basis for the reduction from ₱1,350,828.00 to ₱209,183.42, are valid given that similar issues had already been settled in prior decisions.
Evidentiary and Substantive Questions
- Whether the act of modifying the award based on evidence that should have been presented earlier constitutes a grave abuse of discretion.
- Whether the execution of a final judgment can be re-opened for re-evaluation of facts or corrected solely for clerical or nunc pro tunc adjustments.
Abuse of Discretion
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)