Case Digest (G.R. No. 175371)
Facts:
The case involves Benito J. Brizuela as the petitioner and Abraham Dingle and Nicandro Legaspi as the respondents. The events leading to the case began when Dingle and Legaspi were employed by Philippine Media Post, Inc. (PMPI), the publisher of the newspaper Philippine Post. Dingle was hired as an Associate Editor on July 20, 1999, and confirmed as a regular employee on September 23, 1999, with a monthly salary of P22,000. Legaspi started as a City Editor on November 9, 1999, and was later promoted to News Editor on January 7, 2000, earning P25,000 monthly. On May 19, 2003, both respondents filed a complaint against PMPI and Brizuela for various claims, including nonpayment and underpayment of salaries, editorial fees, and other benefits. They alleged that they worked six days a week, often on holidays, without receiving overtime pay. The situation escalated when, on November 16, 2000, the employees, including Dingle and Legaspi, ceased publication due to unpaid salaries. Br...
Case Digest (G.R. No. 175371)
Facts:
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.
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.
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.
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.
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.
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.
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:
- (Unlock)
Ruling:
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Ratio:
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.
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.
Social Justice Principle:
- Employees deprived of their livelihood should be provided immediate relief, even during the pendency of appeals.
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.
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.