Title
Galvez vs. Philippine Long Distance Telephone Co.
Case
G.R. No. L-16370
Decision Date
Oct 31, 1961
Jose Galvez's widow contested PLDT's pension plan adjustments after his 38-year service; SC upheld finality of CIR's order, awarding her P13,028.64 despite prior P24,000 payment.
A

Case Digest (G.R. No. L-16370)

Facts:

  • Background and parties
    • Gracia Vda. de Galvez, widow and heir of Jose S. Galvez, is petitioner.
    • Philippine Long Distance Telephone Company is respondent employer.
    • Court of Industrial Relations is the other respondent in the administrative proceedings.
    • The dispute arises from distribution of benefits under the Employees' Pension Plan adopted by the Company on September 18, 1923.
  • Employment history and pension payments
    • Jose S. Galvez was employed by the Company from December 1, 1908 to December 31, 1941 (33 years and 1 month) when operations were disrupted by the Japanese invasion.
    • He was reinstated on April 1, 1945 and served until his death on February 7, 1951 (additional 5 years, 10 months and 6 days); total service aggregated 38 years, 11 months and 6 days.
    • In 1951, the Company paid Gracia Vda. de Galvez P24,000 as pension and death benefits under the Employees' Pension Plan.
  • Administrative proceedings instituted by prewar employees
    • On December 22, 1951, Crispin Jeturian and about sixty-three other prewar employees instituted a proceeding in the Court of Industrial Relations for collection of their proportionate shares in the Employees' Pension Plan, alleging the Plan had been discontinued by a Board resolution dated November 6, 1945, made retroactive to January 1, 1942.
    • On February 23, 1954, the Court of Industrial Relations issued a decision (Case No. 639-V) directing payment of proportionate shares in the pension plan and, for those employees who had not received a 30-day notice of dismissal prior to resumption of business in 1946, severance pay equivalent to one month's salary.
    • The Supreme Court affirmed that decision in Philippine Long Distance Telephone Co. vs. Jeturian, et al., G. R. No. Lr-7756, decided June 20, 1955.
  • Liquidation, examiner's report, and orders for payment to nonpetitioners
    • The Court of Industrial Relations ordered liquidation of the prewar pension plan and appointed a chief examiner.
    • The examiner's report, approved by the Court by order dated May 12, 1956, specified all prewar employees entitled to participate and the amount due each.
    • The report included names of several persons who had not been petitioners in Case No. 639-V, whose aggregate share was P23,381.96; among them was Jose S. Galvez, whose share was P13,028.64.
    • These nonpetitioners, including Gracia Vda. de Galvez on behalf of her deceased husband, requested payment of their shares pursuant to the examiner's report.
    • Despite the Company's opposition that the claimants were not parties and thus could not invoke the prior decisions, the Court of Industrial Relations issued an order dated January 8, 1959 directing the Company to deposit P23,381.96 (exclusive of service fee) with the Court cashier.
    • The Court of Industrial Relations, sitting en banc, affirmed the January 8, 1959 order in a resolution dated February 14, 1959.
  • Company's petitions and subsequent proceedings concerning the share of Jose S. Galvez
    • The Company filed a petition for certiorari with the Supreme Court, docketed G. R. No. L-15120, seeking review of the January 8 and February 14, 1959 orders; that petition was dismissed by resolution of the Supreme Court dated March 17, 1959 for lack of merit.
    • On or about April 14, 1959, the Company filed with the Court of Industrial Relations a petition asking not to be required to deposit the P13,028.64 share of Jose S. Galvez, asserting that Gracia Vda. de Galvez had already received P24,000 and that under the pension rules post-liberation service would have yielded only six months' pay (P12,000), but that the Company had given the ...(Subscriber-Only)

Issues:

  • Authority of the Court of Industrial Relations to alter a previously issued and affirmed order
    • Whether the Court of Industrial Relations had authority to alter or modify its January 8, 1959 order, after that order had been affirmed en banc and a certiorari petition to the Supreme Court (G. R. No. L-15120) was dismissed.
  • Finality and executory character of the January 8, 1959 order and its effect on subsequent modification
    • Whether the January 8, 1959 order awarding P13,028.64 to Jose S. Galvez had become final and executory and therefore was beyond the power of the Court of Industrial Relations to change.
    • Whether equitable considerations discovered by the Court of Industrial Relations could justify reopening an executory order.
...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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