G.R. No. 142456 - Berona vs. Sandiganbayan

Petitioners: Archilles Manufacturing Corporation, Alberto Yu (Chairman), and Adrian Yu (Vice-President).
Private Respondents: Geronimo Manuel, Arnulfo Diaz, Jaime Carunungan, and Benjamin Rindon; employed as laborers at Archilles’ steel factory in Barangay Pandayan, Meycauayan, Bulacan, earning a daily wage of P96.00.
Workplace Provision: A bunkhouse maintained by Archilles served as a resting place for workers, including the respondents.

Background Incident: In 1988, a near-mauling incident involving a relative of an employee prompted Archilles to forbid workers from bringing family members into the bunkhouse.
Continued Violation: Despite the prohibition, private respondents continued to bring their families, causing disturbances such as discomfort among other workers and unsanitary conditions (e.g., corridors littered with children’s bowels and urine, and noise disturbances from crying children).
Management Action: On May 11, 1990, the management directed the respondents to remove their families from the bunkhouse and to explain the breach of company policy.

Employee Non-compliance & Abandonment: Although the respondents complied by removing their families, they failed to report for an explanation and were absent from May 14 to May 18, 1990.
Termination: On May 18, 1990, Archilles terminated the employment of the respondents for both abandonment and violating the bunkhouse rule.
Labor Arbitrator’s Ruling: On July 10, 1991, the Labor Arbiter ruled that the dismissal was illegal. The decision ordered the immediate reinstatement of the respondents along with payment of backwages, proportionate 13th month pay for 1990, and attorney’s fees.

On September 10, 1991, the respondents filed with the National Labor Relations Commission (NLRC) a motion for the issuance of a writ of execution for immediate reinstatement (either physically or in the company payroll).
Archilles opposed this motion on September 19, 1991.
Due to inaction on the initial motion, the respondents filed a similar motion on July 15, 1992, which also remained unresolved.

The NLRC vacated the Labor Arbiter’s decision and ruled that the respondents’ dismissal was valid, stating that they wilfully disobeyed a lawful order to explain their infraction.
However, regarding the “withheld” salaries, the NLRC ordered Archilles to pay the respondents for the period from September 19, 1991 (when the motion was opposed) until the NLRC decision was promulgated on August 11, 1992.
The ruling also affirmed the award of proportionate 13th month pay for 1990 and ordered payment of attorney’s fees amounting to 10% of the total judgment award (P12,351.30, part of a total of P123,513.00).

A subsequent motion for partial reconsideration by the NLRC, dated September 8, 1992, was denied.
Petitioners then filed the instant petition seeking partial annulment of the NLRC decision and its resolution with respect to the order for “withheld” salaries and the award of attorney’s fees.

Whether a writ of execution is still necessary to enforce the Labor Arbiter’s order of immediate reinstatement pending appeal, even though the decision is declared “immediately executory.”

Whether an employee dismissed for cause forfeits the right to receive a 13th month pay, particularly the proportionate benefit for the year 1990.

Whether it is proper to award attorney’s fees in the instant case, especially considering that such an award is typically reserved for cases involving unlawful withholding of wages.