Case Digest (G.R. No. 251518)
Facts:
This case involves Del Monte Land Transport Bus Company (DLTB), Don L. Morales, and Eileen Flores as petitioners and Romeo M. Jaranilla, Marlon H. Guantero, and Jesus B. Domanais as respondents. The respondents filed consolidated complaints for illegal dismissal and claims for full backwages and reinstatement against the petitioners. On November 25, 2013, Labor Arbiter (LA) Benedict G. Kato ruled that respondents were illegally dismissed and granted their complaints. The petitioners appealed to the National Labor Relations Commission (NLRC), which reversed the LA's decision on April 23, 2014, dismissing respondents' complaints. Respondents moved for reconsideration, and the NLRC reinstated the LA's decision on October 31, 2014. Petitioners then filed a Petition for Certiorari with the Court of Appeals (CA) while respondents secured a Writ of Execution on the LA’s order. Partial payments were made to respondents based on this writ.Later, the CA granted petitioners’ certiorari p
Case Digest (G.R. No. 251518)
Facts:
- Parties and procedural posture
- Petitioners are Del Monte Land Transport Bus Company (DLTB), Don L. Morales, and Eileen Flores.
- Respondents are Romeo M. Jaranilla, Marlon H. Guantero, and Jesus B. Domanais.
- Petitioners filed a Petition for Review on Certiorari under Rule 45, assailing the CA Decision in CA-G.R. SP No. 151070 dated March 14, 2019, which affirmed the NLRC Resolution dated January 30, 2017.
- Origin of the case
- Respondents filed consolidated complaints for illegal dismissal, full backwages, and reinstatement against petitioners.
- On November 25, 2013, Labor Arbiter (LA) Benedict G. Kato issued a Decision granting the complaints, ruling respondents were illegally dismissed.
- Petitioners appealed to the NLRC.
- NLRC and subsequent rulings
- On April 23, 2014, the NLRC issued a Decision reversing the LA and dismissing respondents’ complaints.
- Respondents moved for reconsideration; on October 31, 2014, the NLRC granted the motion and reinstated the LA Decision.
- Petitioners filed a Petition for Certiorari with the CA challenging the October 31, 2014 Resolution.
- Execution and partial payments
- Pending the CA petition, respondents secured a Writ of Execution based on the LA Decision, leading to issuance of a check amounting to PHP 1,189,364.42 as partial payment.
- Balance was secured from petitioners’ cash bond.
- On March 27, 2015, the LA ordered respondents to be released the amounts due, evidenced by disbursement vouchers showing each respondent received over PHP 387,000 exclusive of tax.
- CA ruling on certiorari
- On June 30, 2015, the CA granted petitioners’ Petition for Certiorari, annulling the NLRC Resolution of October 31, 2014.
- The CA held respondents were legally dismissed and that petitioners complied with the two-notice rule.
- The CA decision became final and executory on November 24, 2015.
- Motion for Alias Writ of Execution and rulings
- Respondents filed a motion for Alias Writ of Execution, claiming entitlement to reinstatement wages from December 2014 up to the finality of the CA decision.
- Labor Arbiter Irene Castro De Quiroz, after hearing, granted the motion on August 30, 2016, ordering reinstatement wages from November 25, 2013 to April 23, 2014 (period of first LA ruling) and from October 31, 2014 to June 30, 2015 (period after NLRC reinstated LA ruling until CA reversed it).
- Petitioners appealed to the NLRC.
- The NLRC dismissed the petitioners’ appeal for lack of merit, holding respondents are entitled to accrued salaries for the periods where LA order was in effect even if eventually declared legally dismissed.
- Petitioners’ Motion for Reconsideration was denied.
- Court of Appeals decision on certiorari
- The CA upheld the NLRC ruling, reasoning that the October 31, 2014 NLRC Resolution revived the LA Order which is immediately executory.
- The CA agreed respondents are entitled to reinstatement wages from November 25, 2013 to April 23, 2014 and October 31, 2014 to June 30, 2015.
- Petitioners’ Motion for Reconsideration was denied.
- Petitioners’ submission before the Supreme Court
- Petitioners argued the CA gravely erred in allowing reinstatement wages during the period the NLRC had reversed the LA decision (April 23 to October 31, 2014) and disregarded their right to restitution after the CA’s final decision.
- Claiming that reinstatement effect ceased upon the April 23, 2014 NLRC decision and that reinstatement upon NLRC’s reconsideration was not immediately executory.
- Petitioners contend that after CA’s final decision, respondents are no longer entitled to accrued wages.
Issues:
- Whether respondents are entitled to reinstatement wages during the period from October 31, 2014 to June 30, 2015 when the NLRC reinstated the LA Order even though the CA later reversed this ruling.
- Whether the CA erred in disregarding petitioners' right to restitution given the final nullification of the October 31, 2014 NLRC Resolution by the CA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)