Title
Supreme Court
BPI Employees Union-Metro Manila vs. Bank of the Philippine Islands
Case
G.R. No. 178699
Decision Date
Sep 21, 2011
Bank teller Zenaida Uy was illegally dismissed; Supreme Court ordered reinstatement with back wages based on pre-dismissal salary, excluding post-dismissal benefits, and imposed 12% interest.

Case Digest (G.R. No. 178699)
Expanded Legal Reasoning Model

Facts:

  • Employment and Dismissal
    • Zenaida Uy was employed as a bank teller at the Bank of the Philippine Islands’ (BPI) Escolta Branch.
    • On December 14, 1995, Uy’s services were terminated on grounds of gross disrespect/discourtesy toward an officer, insubordination, and absence without leave.
    • Following her dismissal, Uy, together with the BPI Employees Union-Metro Manila (the Union), filed a case for illegal dismissal.
  • Procedural History and Initial Adjudications
    • On December 31, 1997, the Voluntary Arbitrator rendered a decision finding Uy's dismissal illegal.
      • The decision ordered the immediate reinstatement of Uy.
      • It also directed BPI to pay her full back wages from the time of dismissal until actual reinstatement, including all benefits under the Collective Bargaining Agreement (CBA) and attorney’s fees.
    • On October 28, 1998, the Court of Appeals (CA) affirmed with modifications:
      • Instead of reinstatement, the CA ordered BPI to pay separation pay.
      • The CA limited the award of back wages to a period of three years.
    • Subsequently, both parties filed petitions for review.
      • BPI’s petition (G.R. No. 137856) was dismissed for failure to comply with the certification of non-forum shopping.
      • Uy’s and the Union’s petition (G.R. No. 137863) was given due course.
    • On March 31, 2005, the Supreme Court issued a decision modifying the earlier CA ruling:
      • It directed BPI to pay back wages from the time of illegal dismissal until actual reinstatement.
      • It also ordered Uy’s reinstatement to her former position or a substantially equivalent one, preserving seniority rights and attendant benefits.
  • Computation and Dispute on Back Wages
    • In the execution proceedings after the March 31, 2005 decision:
      • Uy computed her back wages based on the current wage level, including all wage increases and additional benefits such as COLA, financial assistance, quarterly bonus, CBA signing bonus, uniform allowance, medicine allowance, dental care, medical/doctor’s allowance, teller’s functional allowance, vacation and sick leave credits, holiday pay, anniversary bonus, burial assistance, and an omega watch.
      • BPI contended that the computation should be based solely on the salary rate and regular allowances received at the time of dismissal.
    • On December 6, 2005, the Voluntary Arbitrator issued an order:
      • The order largely agreed with Uy’s and the Union’s contention regarding full back wages but excluded certain items (uniform allowance, anniversary bonus, and omega watch) due to lack of proof that they were granted at the time of dismissal.
      • The total computed back wages by the arbitrator amounted to P3,897,197.89.
  • Court of Appeals Intervention and Further Modifications
    • BPI filed a petition for certiorari before the CA alleging:
      • Grave abuse of discretion by the Voluntary Arbitrator for computing back wages based on the current rate and including post-dismissal benefits.
      • The CA was urged to issue a temporary restraining order (TRO) and/or writ of preliminary injunction to halt the execution of the Voluntary Arbitrator’s order.
    • The CA issued a TRO restraining the implementation of the December 6, 2005 order and the corresponding writ.
    • In its Amended Decision dated July 4, 2007, the CA:
      • Upheld the propriety of BPI’s resort to certiorari.
      • Revised the computation of back wages to be based on Uy’s basic salary at the time of dismissal—P10,895.00—as the base figure, plus only the regular allowances she was receiving at that time.
      • Deleted awards for benefits such as the CBA signing bonus, medicine allowance, medical/doctor’s allowance, and dental care allowance due to insufficient evidence of their prior grant.
      • Retained the awards for COLA, quarterly bonus, financial assistance, teller’s functional allowance, holiday pay, and the monetary conversion of vacation and sick leave (subject to further proof on the latter).
      • Affirmed the award of attorney’s fees, noting these had achieved finality.
  • Consolidation and Subsequent Developments
    • The petitions in G.R. Nos. 178699 and 178735 were consolidated.
    • Uy and the Union argued that the CA had effectively amended the Supreme Court’s March 31, 2005 decision, particularly on issues not raised in that case.
    • BPI challenged:
      • The inclusion of benefits not necessarily part of “full back wages.”
      • The propriety of including the teller’s functional allowance and cash conversion of leave credits.
      • The manner of service of the petition.
    • Eventually, the Court resolved:
      • The computation of back wages should be strictly based on the salary rate at the time of dismissal and the regular allowances then received.
      • A legal interest of 12% per annum should be applied on the monetary award from the finality of the March 31, 2005 decision until full satisfaction.
      • Uy’s reinstatement, although previously restrained by the TRO, had effectively occurred on August 1, 2006, rendering that aspect moot.

Issues:

  • The Proper Computation of Back Wages
    • Whether the computation of back wages should include all wage increases and benefits granted during the period of dismissal or be confined to the basic salary plus regular allowances received at the time of dismissal.
    • Whether the term “full back wages” under Republic Act No. 6715 is to be understood as including post-dismissal increments and extra benefits under the CBA.
  • The Validity of the CA’s Modifications and the TRO
    • Whether the CA’s modification of the computation of back wages, by excluding salary increases and certain benefits, is in conformity with settled jurisprudence.
    • Whether the issuance of the temporary restraining order (TRO), which effectively restrained Uy’s reinstatement, was proper and its scope proper given the finality of the March 31, 2005 decision.
  • The Issue of Service and Proper Mode of Appeal
    • Whether BPI’s petition for certiorari under Rule 65 was the proper remedy.
    • Whether Uy’s/Union’s petition complied with procedural requirements regarding service and certification of non-forum shopping.
  • The Inclusion of Specific Benefits and Attorney’s Fees
    • Whether benefits such as the teller’s functional allowance, vacation and sick leave cash conversion, and various allowances not proven to have been received at the time of dismissal should be included in the computation of back wages.
    • Whether the award of attorney’s fees, as part of the total monetary award, is proper given its previous resolution in earlier proceedings.
  • The Application of Legal Interest
    • Whether an interest rate of 12% per annum should be imposed on the total monetary award from the finality of the final decision until full compliance.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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