G.R. No. 103638 - 1st Intramuros BF Condominium Corp. vs. National Labor Relations Commission

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G.R. No. 103638: 1st Intramuros BF Condominium Corp. vs. National Labor Relations Commission

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Title Source: Supreme Court: 1st Intramuros BF Condominium Corp. vs. National Labor Relations Commission

Case: G.R. No. 103638

Decision Date: Apr 14, 1994

Employee disputes salary computation and promotions; labor arbiter rules in her favor, upheld by NLRC. Supreme Court approves compromise agreement, settling claims amicably.

Case Digest (G.R. No. 103638)
Expanded Legal Reasoning Model

Facts:

Employment and Promotion of Private Respondent

On February 1, 1980, Nancy Dingayan Quimpo was employed by First Intramuros BF Condominium Corporation as Assistant Building Administrator for Finance and Administration.
She received successive promotions and corresponding salary increases:

In 1984, promoted to Senior Assistant Building Administrator.
In 1985, promoted to Building Administrator.
In 1986, promoted to General Manager.

In 1987, another salary increase was effected by the company’s president.

Dispute on Salary Computation and Benefits

On November 29, 1988, upon receiving her 13th month pay based solely on her basic salary, private respondent protested.
She contended that the company’s usual policy was to include other fringe benefits in the computation of her 13th month pay.
Subsequently, her salary was reverted to ₱8,107.50, the amount she received in November 1987, allegedly because the December 1986 salary increase had not been confirmed by the Board of Directors.

Initial Filing and Labor Arbitral Decision

The private respondent filed a complaint for underpayment, withholding of salary, and diminution of her 13th month pay.
Labor Arbiter Manuel P. Asuncion rendered a decision on June 20, 1990:

Ordered payment of the complainant’s full salary at ₱22,311.24 from December 1988, with legal interest.
Awarded 13th month pay for 1987 in the amount of ₱6,200.00.
Awarded moral and exemplary damages of ₱250,000.00.
Imposed a 10% attorney’s fee on the benefits awarded.

Appeal to the National Labor Relations Commission (NLRC)

Petitioners appealed the Labor Arbiter’s decision.
On September 24, 1991, the NLRC affirmed the Labor Arbiter's decision, dismissing the appeal for lack of merit.
A motion for reconsideration was filed by the petitioners.
On December 27, 1991, the NLRC dismissed the motion for reconsideration, reinforcing its previous resolution.

Petition for Certiorari Before the Supreme Court

On February 7, 1992, Petitioners filed a petition for certiorari with the Supreme Court.
The petition alleged that:

The public respondent acted without or beyond its jurisdiction or with grave abuse of discretion by validating the salary increases.
The commission erred in sustaining the award of moral damages.
The commission erred in sustaining the award of attorney’s fees.

Petitioners also requested the issuance of a temporary restraining order.

Temporary Restraining Order and Subsequent Developments

On March 2, 1992, the Supreme Court issued a temporary restraining order, requiring the petitioners to post a cash or surety bond during the pendency of the case.
The temporary restraining order was lifted on July 22, 1992, due to the petitioners’ failure to post the required bond as directed in an interim resolution on May 18, 1992.

Compromise Agreement and Joint Motion

On September 23, 1992, the Supreme Court gave due course to the petition and required the parties to submit their memoranda.
On February 15, 1994, both parties filed a “Joint Motion to Render Decision Based on the Compromise Agreement.”
Under the compromise agreement reached on January 29, 1994:

First Intramuros BF Condominium Corp. agreed to pay Nancy J. Dingayan-Quimpo a total of ₱1,200,000.00.
The payment schedule was detailed in six installments:

₱300,000.00 on February 1, 1994.
₱300,000.00 on March 1, 1994.
₱150,000.00 on April 1, 1994.
₱150,000.00 on May 1, 1994.
₱150,000.00 on June 1, 1994.
₱150,000.00 on July 1, 1994.

The compromise was intended to fully settle claims for backwages, separation pay, damages, and attorney’s fees.
Both parties waived any future claims related to the case.

The Supreme Court found that the compromise agreement was not contrary to law, morals, good customs, public order, or public policy.

Final Resolution

The Supreme Court approved the compromise agreement as its decision.
The Court enjoined the parties to faithfully comply with the terms and conditions of the agreement.
The resolution was declared immediately executory without costs.

Issues:

Jurisdiction and Discretion

Whether the NLRC acted without or beyond its jurisdiction or with grave abuse of discretion in sustaining:

The decision validating the salary increase granted to the private respondent.
The decision awarding moral damages.
The decision awarding attorney’s fees.

Validity of the Compromise Agreement

Whether the compromise agreement, as entered by the parties to amicably resolve their disputes, is valid and enforceable.
Whether the agreement is contrary to law, morals, good customs, public order, or public policy.

Procedural and Provisional Matters

Whether the temporary restraining order issued by the Supreme Court was appropriately granted and later lifted based on the petitioners’ failure to post the required bond.
Whether the parties’ joint motion to render decision based on the reached compromise adequately disposes of the pending claims.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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END