G.R. No. L-16370 - Galvez vs. Philippine Long Distance Telephone Co.

Jose S. Galvez was employed by the Philippine Long Distance Telephone Company.
His prewar service spanned from December 1, 190B (assumed to be a typographical error for a proper year) to December 31, 1941, totaling 33 years and 1 month before the Japanese invasion disrupted operations.
After the liberation of the Philippines on April 1, 1945, he was reinstated and rendered an additional five years, ten months, and six days of service until his death on February 7, 1951.
In all, his aggregated service prior to and after the war amounted to 38 years, 11 months, and 6 days.

The Company implemented an Employees’ Pension Plan on September 18, 1923.
Following Mr. Galvez’s death, his widow, Gracia Vda. de Galvez, received P24,000 as pension and death benefits derived from the said plan.
The plan provided different compensation schemes:

Prewar service was rewarded with a full 12-month pay benefit for those who had served for ten or more years.
Post-liberation service, based on a monthly compensation of P2,000, was calculated to yield a 6-month pay benefit (P12,000) due to the duration of service generally falling short of ten years.

On December 22, 1951, Crispin Jeturian and approximately 63 other prewar employees filed a petition in the Court of Industrial Relations to claim their proportionate shares in the pension plan.
A decision was rendered on February 23, 1954 (Case No. 639-V), awarding each petitioner their respective shares and severance pay where applicable.
The decision was subsequently affirmed by the Supreme Court in G.R. No. L-7756 on June 20, 1955, albeit with slight modifications that did not affect the substantive outcome.

The Court of Industrial Relations, through its chief examiner’s report approved on May 12, 1956, liquidated the prewar pension plan.
The report itemized all prewar employees entitled to receive a portion of the pension fund, including a specified share for Jose S. Galvez amounting to P13,028.64.
Following the report, non-petitioners, such as Mrs. Galvez, subsequently moved for the payment of their respective shares as identified in the examiner’s report.

The Court of Industrial Relations issued an order on January 8, 1959, directing the Company to deposit a total sum of P23,381.96 (which included the aggregate shares for non-petitioners) with the Court.
On the Company’s motion for reconsideration, the order was affirmed en banc on February 14, 1959.
The Company then filed a petition for review by certiorari before the Supreme Court (docketed as G.R. No. L-15120) on February 28, 1959, contesting the deposit order, but this petition was dismissed as lacking merit on March 17, 1959.
On April 14, 1959, the Company petitioned the Court of Industrial Relations to be relieved from depositing Jose S. Galvez’s share of P13,028.64, asserting that Mrs. Galvez had already received P24,000 based on erroneous computation favoring prewar service.

By an order dated September 8, 1959, the Court of Industrial Relations determined:

Given that Mrs. Galvez had received P24,000, the remaining balance due was computed as P1,028.64.
The Company’s subsequent motion for reconsideration was denied, leading Mrs. Galvez to seek review by certiorari for the September 8, 1959 order.
The lower court justified its action by stating that it was exercising sound discretion to correct an “error” that might cause injustice, effectively modifying its earlier, already final, January 8, 1959 order.

Whether the Court of Industrial Relations possessed the authority to alter or modify its final and executory order (January 8, 1959) merely on the basis of equitable considerations, even if such modification aimed at doing justice to the aggrieved party.
Whether the modification effected by the September 8, 1959 order, which recalculated and adjusted the pension benefit due to Jose S. Galvez (and by extension to his heirs), was legally tenable.

Whether the doctrine of finality renders the earlier order (January 8, 1959), which awarded P13,028.64 to Jose S. Galvez, immune from subsequent modification by the issuing court.
Whether the equitable considerations cited by the Court of Industrial Relations can override the policies ensuring that final orders are definitively closed to prevent endless litigation.

Whether Mrs. Galvez, as the legal heir of Jose S. Galvez, is entitled to a modification of her pre-determined share based on the recalculation of the pension benefits.
Whether the Company’s procedural arguments for relief from depositing the said share are justified in light of the already executed and final orders.