G.R. No. 161032 - Tulfo vs. People

The case arose from proceedings involving petitioner Coca-Cola Bottlers Philippines, Inc. and respondents including Alan M. Agito, Regolo S. Oca III, Ernesto G. Alariao, Jr., Alfonso Paa, Jr., Dempster P. Ong, Urriquia T. Arvin, Gil H. Francisco, and Edwin M. Golez.
The underlying dispute pertained to the termination of the respondents and whether an employer-employee relationship existed between the parties.
Prior decisions by the Court of Appeals (Decision dated February 19, 2007 and Resolution dated August 31, 2007 in CA-G.R. SP No. 85320) had determined that such an employer-employee relationship did exist.

On February 13, 2009, the Supreme Court issued a Decision in which it denied the petition filed by the petitioner but partially affirmed the Court of Appeals’ decisions.
Instead of remanding the matter back to the National Labor Relations Commission (NLRC) as had been ordered by the appellate court, the Supreme Court directly ordered remedial relief.
The remedial orders included:

Reinstatement of the respondents without loss of seniority rights.
Payment of full back wages computed from the time their compensation was unjustly withheld until their actual reinstatement.

On April 13, 2009, respondents filed a Motion for Clarification and/or Partial Motion for Reconsideration.
The motion highlighted the need to include the words “inclusive of allowance and x x x other benefits or the monetary equivalent thereof” in the dispositive part of the Decision.
Respondents argued that the inclusion of such words was necessary to ensure that all forms of compensation legally due were considered in the computation of “full back wages.”

The Supreme Court examined the motion and determined that the contested words were descriptive clarifications of “full back wages.”
It noted that these words did not amount to a new or additional award, but rather served to clarify the extent of the back wages.
Subsequent to this evaluation, the Court modified the dispositive part of its February 13, 2009 Decision to include the clarifying language.
The final modified dispositive part ordered:

That respondents had been illegally dismissed.
That petitioner be ordered to reinstate the respondents without loss of seniority rights.
That petitioner be ordered to pay the respondents full back wages, inclusive of allowances and other benefits (or their monetary equivalent) computed from the time their compensation was withheld until their actual reinstatement.

The existence and recognition of an employer-employee relationship between petitioner and respondents.

Whether the relationship justified the protection offered under labor laws.
Validation of the procedural findings from the Court of Appeals regarding such relationship.

Whether the dismissal of respondents was indeed illegal.
The ensuing entitlements of the respondents—including reinstatement and the award of full back wages.

Whether the remedies (reinstatement without loss of seniority and full back wages computed appropriately) adequately remedied the illegal dismissal.
The importance of including clarifying language (i.e., “inclusive of allowance and x x x other benefits or the monetary equivalent thereof”) within the dispositive part of the decision.

How Article 279 mandates the computation of full back wages.
Whether the computed back wages should cover not just basic salary but also allowances and other benefits.