G.R. No. 207791 - City of Davao vs. Intestate Estate of Dalisay

Petitioners: Angelito Castro, Raymundo Saura, and Ramonito Fanuncion, who were among the union officers and members dismissed from their employment.
Respondents: Philippine Long Distance Telephone Company (PLDT) and Manuel V. Pangilinan.

PLDT is a domestic telecommunications corporation.
Petitioners were among 94 employees dismissed for participating in a strike staged by the Manggagawa ng Komunikasyon sa Pilipinas (MKP) from December 22, 1992 to January 21, 1993.
The strike was later declared illegal, and petitioners’ dismissals were adjudged valid by the National Labor Relations Commission (NLRC) in a Resolution dated February 27, 1998.

Although petitioners were initially reinstated upon the filing of their complaints for illegal dismissal, money claims, and damages, they ultimately received termination notices in separate letters on January 12, 1999.
Their claims were based on allegations that, during their continued employment post-strike until the termination notice, PLDT had extended benefits such as redundancy/early retirement programs and promotions, which petitioners argued amounted to a waiver or condonation of the illegal strike offense.
Labor Arbiter Vicente R. Layawen, in his Decision on March 15, 2000, declared their dismissal illegal and ordered PLDT to reinstate them along with payment of backwages (with interest) and attorney’s fees.
Subsequently, the NLRC vacated the Labor Arbiter’s Decision on December 28, 2000, however awarding a form of financial assistance to petitioners for equitable and humanitarian reasons.

A new CBA was signed on March 14, 2001 between MKP and PLDT, which granted all PLDT employees a benefit of P133,000.00 in lieu of wage increases during the first year of the CBA.

The new CBA was made effective on November 9, 2000, retroactive from the day following the expiration of the old CBA (November 9, 2000).

Petitioners filed motions for execution before the Labor Arbiter to receive payment of this benefit under the new CBA.
Labor Arbiter Jaime M. Reyno, in his Order dated April 18, 2002, adjudged the petitioners as entitled to the payment of P133,000.00 each based on the accrual of the benefit on November 9, 2000, prior to the reversal of the decision granting reinstatement.
The NLRC sustained the Labor Arbiter’s Order in its Resolution dated June 21, 2002 by equating the benefit to those received during reinstatement pending appeal.

The Court of Appeals (CA) rendered a Resolution on November 24, 2009 which set aside the NLRC’s decision by directing each petitioner to return the P133,000.00 received.
The CA found that the petitioners were no longer members of the bargaining unit since they had effectively terminated their employment with PLDT on January 18, 1999, well before the CBA was signed and took effect.
Respondents argued that since the petitioners were not part of the bargaining unit when the new CBA was agreed upon on March 14, 2001, they could not claim its benefits, thereby framing the benefit awarded as a case of unjust enrichment.

Whether petitioners are entitled to the CBA-imposed benefit of P133,000.00 each, given that the new CBA became effective on November 9, 2000 and was signed on March 14, 2001.
Whether the retroactive effect of the CBA’s date of accrual (November 9, 2000) overrides the fact that petitioners’ employment had already terminated as determined by the finality of earlier resolutions.

Whether petitioners, having been terminated on January 18, 1999, were still considered members of the bargaining unit represented by MKP at the time of the new CBA’s signing and implementation.

Whether granting the P133,000.00 benefit to petitioners who were no longer employees would constitute unjust enrichment.
Whether the principles of res judicata apply, noting that the issue of the validity of the petitioners’ dismissals had been previously decided with finality.