Case Digest (G.R. No. L-30822)
Facts:
Eduardo Claparols, Romulo Agsam and/or Claparols Steel and Nail Plant v. Court of Industrial Relations, Allied Workers' Association, et al., G.R. No. L-30822. July 31, 1975. The Supreme Court First Division. Makasiar, J., writing for the Court.Petitioners are the owners/operators of the Claparols business entities; private respondents are the Allied Workers' Association and ten dismissed employees (including Demetrio Garlitos, Alfredo Ongsuco, and others). In August 1957 the workers filed a complaint for unfair labor practice (ULP) with the Court of Industrial Relations (CIR) alleging dismissal for union activities.
On September 16, 1963 the CIR found Eduardo Claparols guilty of union busting, ordered the respondents to cease and desist, to reinstate the complainants to former or equivalent jobs, and to pay back wages from dismissal until reinstatement. Petitioners' motion for reconsideration was denied by the CIR en banc on January 27, 1964. After a motion for execution filed March 30, 1964, the CIR on May 14, 1964 (and again November 10, 1964) ordered reinstatement and directed an examiner to examine payrolls and compute back wages.
Attempts in December 1964 to effect reinstatement were resisted by company personnel. The CIR examiner submitted on January 15, 1965 three alternative computations of back wages because the original Claparols Steel and Nail Plant ceased operations June 30, 1957 and a Claparols Steel Corporation succeeded it on July 1, 1957 and ceased operations December 7, 1962. Petitioners opposed the examiner's report (Jan. 23, 1965), arguing that, under the Court's ruling in Sta. Cecilia Sawmills v. CIR (L-19273-74), recoverable back wages should be limited to three months and that liability could not extend beyond December 7, 1962 when the successor corporation stopped operations; respondents countered that the entities were one and the same.
After hearings, the CIR on November 28, 1966 approved the examiner's report and directed recomputation of back wages and bonuses. Petitioners moved for reconsideration (Dec. 7, 1966); the CIR dismissed it as pro forma on February 8, 1967. Petitioners then filed a certiorari petition with the Supreme Court (G.R. No. L-27272) challenging the November 28, 1966 order; that petition was denied by the Supreme Court on April 27 and May 19, 1967.
Further motions to recompute were made; the CIR's chief examiner produced a March 21, 1968 report itemizing bonuses totaling P9,107.79 for the ten workers. After the parties filed oppositions, rejoinders and a "constancia," the CIR on May 30, 1969 issued the order under review approving the examiner's report and directing petitioners to pay the respective back wages and bonuses. Petitioners moved for...(Pro-only)
Issues:
- Is the present petition barred by the Supreme Court's prior denial of a certiorari petition in G.R. No. L-27272 (i.e., does the prior resolution constitute the law of the case)?
- Are the annual bonuses computed by the CIR recoverable as part of back wages although bonuses were not expressly adjudicated in the CIR's original September 16, 1963 decision?
- Should recoverable back wages (including bonuses) be limited by the Sta. Cecilia Sawmills rule to three months because the business ceased operations, or does corporate succession and the facts ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)