G.R. No. 202542 - Angono Medics Hospital, Inc. vs. Agabin

Antonina Q. Agabin was hired by Angono Medics Hospital, Inc. (AMHI) on September 1, 2002, as a staff midwife earning a monthly salary of P3,500.00.
While employed, Agabin was allowed by the then-administrators, Andres Villamayor (President) and Antoinette E. Antiojo (Chief Nurse), to pursue nursing studies.

On June 23, 2007, Agabin requested a leave without pay from June 29, 2007 to September 15, 2007 to work as part of a school requirement, and her request was approved by Antiojo.
Upon her return on September 15, 2007, Agabin reported to work and was scheduled for duty from September 16 to 30, 2007 (10:00 P.M. to 6:00 A.M. shifts).

On September 19, 2007, during her scheduled duty, Villamayor berated Agabin, ordered her to go home, and stated that she should take a vacation instead of reporting for duty.
Villamayor further warned that Agabin would not be compensated for work done on September 17 and 18, 2007; and the following day, Antiojo informed her that she was no longer required to report for work.

Agabin subsequently filed a complaint alleging illegal dismissal, seeking separation pay, backwages, and other benefits.
AMHI countered that Agabin had simply failed to report for work after June 28, 2007, asserting that abandonment of duty occurred.

The Executive Labor Arbiter, in its December 19, 2008 Decision, found that Agabin was illegally dismissed, upheld her approved leave and reattendance, and awarded her full backwages, separation pay (in lieu of reinstatement), service incentive leave pay, 13th month pay, wages for extra days rendered, and attorney’s fees.
The National Labor Relations Commission (NLRC) in its December 16, 2009 Resolution affirmed the illegal dismissal but modified the award, limiting both backwages (to the period from September 19, 2007 to January 16, 2008) and separation pay (computed from September 1, 2002 up to January 16, 2008), based on Agabin’s rejection of an earlier offer for reinstatement.
Agabin and AMHI’s subsequent motions for reconsideration were denied by the NLRC in its February 26, 2010 Resolution.

AMHI filed a Petition for Certiorari (SP No. 113939) challenging the Labor Arbiter’s procedural handling and the NLRC’s affirmatory ruling, whereas Agabin filed a separate Petition for Certiorari (SP No. 114001) contesting the computation of her monetary awards.
The CA initially dismissed AMHI’s petition in its July 19, 2010 Decision and later reinstated the Arbiter’s December 19, 2008 Decision in the assailed April 27, 2012 Decision (SP No. 114001), holding that the offer of reinstatement was not evidenced and that the computation of awards should extend until finality.
AMHI’s motions for reconsideration before the CA were denied, and disputes arose over whether the CA ruling in SP No. 113939 (G.R. No. 194465) should create res judicata over SP No. 114001 (G.R. No. 202542).

AMHI elevated the case (SP No. 114001) via a Petition for Review on Certiorari, arguing that the earlier CA ruling should bar further questioning of the award computation.
Agabin maintained that the issues in the separate petitions were distinct—illegal dismissal had been finalized and it was the computation of backwages and separation pay that remained in controversy.

Whether the final and executory ruling on Agabin’s illegal dismissal in SP No. 113939 (G.R. No. 194465) precludes the questioning of the computation of her monetary awards in SP No. 114001.
Whether the CA’s earlier decision, regarding the illegal dismissal and its consequences, should bar Agabin from raising issues on the computation of backwages and separation pay in the subsequent petition.

Whether the NLRC’s modification—limiting the computation of backwages (from September 19, 2007 until January 16, 2008) and separation pay (from September 1, 2002 until January 16, 2008)—is correct, given that Agabin had rejected the offer for reinstatement.
Whether backwages should be computed until actual reinstatement or until the finality of the decision, especially in cases where separation pay is awarded in lieu of reinstatement.

How legal interest should be applied to the monetary awards from the time benefits were withheld up to final payment, including varying interest rates over different periods.