Case Digest (G.R. No. L-39742)
Facts:
The case involves Air Manila, Inc. (AMI) and its owner-president, Mr. Ricardo C. Silverio, as petitioners against the Court of Industrial Relations (CIR) and the Air Manila Line Pilots Association (AMILPA), the respondents. The primary dispute originated from a back wages award amounting to P6,018,135.63 by the CIR on August 25, 1971, which was later subject to a reduction of P2,006,045.21 for deductions related to other earnings received by the pilots. The net amount of P4,012,090.42 was determined as due to AMILPA in a per curiam resolution dated June 9, 1978, after several hearings and extensions provided to AMI for satisfying the obligation. Following this resolution, AMI filed for a motion to reconsider the per curiam resolution on August 1, 1978, asking for an abeyance on the enforcement of the writ of execution.
Multiple hearings were conducted, and despite AMI's efforts to negotiate for amended terms of payment—such as offering cash and shares of stock—the AMILPA rej
Case Digest (G.R. No. L-39742)
Facts:
- The case involves petitioner Air Manila, Inc. and its owner-president, Ricardo C. Silverio, facing enforcement proceedings for a backwages award.
- The original award for backwages was computed at P6,018,135.63 based on the approved computation of the Court of Industrial Relations (CIR) emanating from its August 25, 1971 decision.
- A deduction for earnings elsewhere (P2,006,045.21) was applied, reducing the gross award to a net amount of P4,012,090.42 that was due for payment.
Background of the Case
- On June 14, 1978, a writ of execution was issued against petitioner Air Manila, Inc. to effect the payment of the net backwages award.
- On June 9, 1978, the Court, in a per curiam resolution, reiterated the amount due and provided the framework for the execution of the final judgment, also noting that petitioner’s proposals to vary the satisfaction method would not be entertained.
- On June 20, 1978, following the filing of an "Urgent Motion for pre-execution conference and to hold in abeyance writ of execution" by the petitioners, the Court held a special hearing where Mr. Silverio proposed to pay P500,000.00 in cash and the balance in AMI shares as a mode of satisfying the judgment.
- The proposal was ultimately rejected by respondent AMILPA, and the Court granted extensions—initially up to June 28, 1978 and further extended through joint motions—allowing for negotiations between the parties.
- Despite several extensions, the negotiations eventually failed and respondent AMILPA subsequently moved for enforcement of the writ on August 7, 1978.
- The petition for reconsideration filed by Air Manila, Inc. was ultimately denied, and the Court declared its resolution as final and immediately executory.
Procedural History and Enforcement Proceedings
- The case history reveals that the NLRC (successor to the defunct CIR) attempted to reopen the computation of the backwages, which would have provided petitioner Air Manila, Inc. an opportunity to reintroduce evidence regarding pilots' earnings elsewhere.
- This attempt to modify the computation was contrary to the earlier final judgment and res judicata principles, since the approved computation had already been incorporated in a final judgment rendered on June 22, 1975.
- The petitioner’s alternate argument centered on the alleged 2-2-1 decision within the CIR, with accusations that the NLRC’s ensuing action to total reopening was procedurally and substantively flawed.
Conflict on the Computation and Reopening of Issues
- Justice Teehankee filed a concurring opinion stressing that the per curiam resolution was correct in maintaining the finality of the approved computation and that the NLRC’s attempt to re-litigate the matter was barred by res judicata.
- Justice Barredo, in his dissent, argued vigorously that the resolution was procedurally faulty and detrimental to the interests of justice, criticizing both the method of execution and the allowance of a modified computation despite the purported absence of required votes.
- The dissent further emphasized that the petitioner’s alternative proposals deserved more consideration, and he questioned the wisdom of ordering the execution of an award allegedly superseded by the NLRC decision.
Separate Opinions and Dissent
Issue:
- Whether the Court should proceed to enforce the final and executory judgment directing the satisfaction of net backwages despite the petitioner’s attempts to negotiate alternative payment terms.
- The issue of whether the denial of the petition for reconsideration and the ordering of the writ of execution were in accordance with established procedural rules.
Enforcement of a Final Judgment
- Whether the National Labor Relations Commission (NLRC), as the successor to the defunct CIR, possessed the jurisdiction to reopen the computation of the backwages award that had already been rendered final by previous decisions.
- The legal and procedural implications of a 2-2-1 decision within the CIR on the validity of the final award and whether such internal divisions warrant reopening of the issues.
Authority and Jurisdiction
- Whether the doctrine of res judicata should preclude Air Manila, Inc. from re-litigating or attempting to alter the computation of the backwages already approved by the final judgment.
- The effect of any subsequent motions or proposals (including those raised by petitioner’s counsel and filed motions) on the established finality of the judgment.
Applicability of Res Judicata and Finality Principles
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)