Title
Brizuela vs. Dingle
Case
G.R. No. 175371
Decision Date
Apr 30, 2008
Employees of *Philippine Post* sued PMPI and its president for unpaid wages and benefits; court upheld NLRC's final decision, denying Brizuela's TRO request, limiting his liability to official capacity.
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Case Digest (G.R. No. 175371)

Facts:

  1. Parties Involved:

    • Petitioner: Benito J. Brizuela, president and 49% owner of Philippine Media Post, Inc. (PMPI), publisher of the newspaper Philippine Post.
    • Respondents: Abraham Dingle (Associate Editor) and Nicandro Legaspi (News Editor), employees of PMPI.
  2. Employment Details:

    • Dingle was hired as Associate Editor on 20 July 1999, confirmed as regular on 23 September 1999, with a monthly salary of P22,000.
    • Legaspi started as City Editor on 9 November 1999, promoted to News Editor on 7 January 2000, with a monthly salary of P25,000.
  3. Labor Complaint:

    • On 19 May 2003, respondents filed a complaint against PMPI and Brizuela for nonpayment/underpayment of salaries, editorial fees, holiday pay, 13th month pay, separation pay, and other benefits.
    • They alleged they worked six days a week, including holidays, without overtime pay.
    • On 16 November 2000, employees, including respondents, stopped working due to unpaid salaries and benefits.
  4. PMPI’s Defense:

    • PMPI ceased operations in 2000 due to grave financial losses.
    • Brizuela claimed PMPI was in "deep financial trouble" and could not pay employees.
  5. Labor Arbiter’s Decision (30 April 2004):

    • PMPI and Brizuela were ordered to pay Dingle P187,000 and Legaspi P212,000 for separation pay, unpaid salaries, and 13th month pay.
    • Other claims were dismissed.
  6. NLRC Decision (28 October 2005):

    • Modified the Labor Arbiter’s decision, adding vacation and sick leave pay for respondents.
    • Held Brizuela liable only in his official capacity, not personally.
  7. Court of Appeals Proceedings:

    • Brizuela filed a Petition for Certiorari under Rule 65, seeking a Temporary Restraining Order (TRO) to stop the execution of the NLRC decision.
    • The Court of Appeals denied the TRO on 3 May 2006 and the Motion for Reconsideration on 20 September 2006.

Issue:

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Ruling:

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Ratio:

  1. TRO Requirements:

    • A TRO is an extraordinary remedy requiring proof of urgent necessity to prevent irreparable injury.
    • Brizuela’s claim of irreparable injury was speculative, as no writ of execution had been issued yet.
  2. Finality of NLRC Decision:

    • The NLRC decision became final and executory as to PMPI, which did not appeal.
    • Respondents have the right to execute the judgment as a matter of law.
  3. Social Justice Principle:

    • Employees deprived of their livelihood should be provided immediate relief, even during the pendency of appeals.
  4. Corporate Liability:

    • Brizuela is not personally liable but only in his official capacity as PMPI’s president.
    • Any execution on his personal properties can be reversed if his Petition for Certiorari succeeds.
  5. No Grave Abuse of Discretion:

    • The Court of Appeals acted within its discretion in denying the TRO, as Brizuela failed to meet the legal requirements for its issuance.


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