Facts:

The case involves Alemaras Sibal & Sons, Inc. (petitioner) and the National Labor Relations Commission (NLRC), specifically NLM-Katipunan, representing Charito Alimurong and others (respondents). The events unfolded when, on January 30, 1984, the NLM Katipunan filed a notice of strike against Alemaras Sibal & Sons, citing unfair labor practices and illegal dismissals that prompted compulsory arbitration before the NLRC. On April 29, 1985, Labor Arbiter Emilio V. Peñalosa ruled in favor of the respondents, mandating the petitioner to pay separation pay equivalent to one-half month’s salary for each year of service. Subsequently, the NLRC calculated the total payable amount to be ₱207,365.33 on December 23, 1985.

On January 4, 1988, the respondents filed a motion for execution of this decision, which the petitioner did not contest. During a subsequent hearing on April 19, 1988, both parties reached an agreement for a structured payment plan, which included a down payment

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Facts:

Background of the Case

• Petitioner: ALEMARAS SIBAL & SONS, INC.
• Respondents:
• National Labor Relations Commission (NLRC)
• NLM-Katipunan representing the group of Charito Alimurong (private respondent)
• Nature of the Case:
• A petition for certiorari was filed by the petitioner seeking to set aside NLRC resolutions.
• The resolutions dismissed the petitioner’s appeal and upheld the Labor Arbiter’s order for immediate execution of a decision in favor of the private respondent.

Proceedings Involving Unfair Labor Practice and Illegal Dismissal Claims

• January 30, 1984:
• Private respondent filed a notice of strike with the Department of Labor and Employment.
• The notice charged petitioner with unfair labor practices and illegal dismissal.
• The case was elevated to the NLRC for compulsory arbitration.
• April 29, 1985:
• Labor Arbiter Emilio V. PeAalosa rendered a decision.
• The decision ordered petitioner to pay separation pay equivalent to one-half (½) month pay for every year of service.

Computation and Settlement on Separation Pay

• December 23, 1985:
• The Research and Information Unit of the NLRC computed the separation pay, amounting to P207,365.33.
• January 4, 1988:
• The private respondent filed a motion for the execution of the Labor Arbiter’s decision.
• Petitioner did not oppose the motion.
• April 19, 1988:
• A hearing was conducted during which both parties agreed on a computation and payment schedule for the separation pay.
• Settlement Terms:
• Downpayment of P20,736.53 (10% of the total money judgment) to be paid in May 1988.

ii. Subsequent payment of P41,473.06 in June 1988. iii. Payment covering the initial forty-four (44) claim to be made in July 1988. iv. The remaining balance to be spread over a fifteen (15) month period.

Petitioner’s Contentions and Subsequent Motions

• June 10, 1988:
• The Rehabilitation Receiver of petitioner submitted a Manifestation with Motion.
• Petitioner claimed it was under Rehabilitation Receivership pursuant to an SEC order dated August 1, 1984, and hence was not in a position to pay.
• Requested deferment until formal SEC approval of rehabilitation.
• July 18, 1988:
• Owing to failure by petitioner to pay, the Labor Arbiter granted the motion for execution.
• August 5, 1988:
• Petitioner filed a motion for reconsideration, contesting the computation of separation pay by the NLRC’s Research and Information Unit.
• September 9, 1988:
• The motion for reconsideration was denied by Labor Arbiter Jose de Vera.
• Reasons stated:
• The private respondent had not objected to the computation and had previously submitted a proposal regarding the settlement.

ii. Petitioner’s subsequent manifestation to defer execution conflicted with the agreed payment schedule.

Arguments Presented

• Petitioner’s Argument:
• Claimed that the SEC order suspending claims due to rehabilitation receivership justified a stay of execution on the monetary award.
• Argued that the suspension was necessary to allow the rehabilitation receiver to manage the company without undue interference.
• Respondents’ Argument:
• Maintained that petitioner was bound by the settlement agreement with the private respondent regarding the computation and payment of separation pay.
• Emphasized that the execution order from the Labor Arbiter had reached finality and that petitioner’s subsequent motions were untimely.

Issue:

Validity and Effect of the SEC Order

• Whether the SEC order suspending all claims against the petitioner, issued during its rehabilitation receivership, still provided a legal basis to defer the execution of the separation pay after the liquidation process had been initiated.

Timeliness and Merits of the Subsequent Motions

• Whether petitioner’s motions (for reconsideration and suspension of execution) were filed within the allowable period and had merit in light of the agreed settlement.

Enforcement of the Settlement Agreement

• Whether petitioner is legally bound to comply with the settlement agreement that set forth the computation and payment schedule for the separation pay.

Mechanism for Satisfying the Monetary Obligation

• Whether the private respondent should now file its claim with the rehabilitation receiver/liquidator, given the liquidation proceedings and the rules on the preference of credits.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)