Title
Limlingan vs. Asian Institute of Management, Inc.
Case
G.R. No. 220481
Decision Date
Feb 17, 2016
Limlingan and Leyco file a complaint against AIM for illegal suspension and non-payment of salaries, leading to a series of appeals and modifications in the decision, ultimately resulting in the Supreme Court ruling in favor of the employees, awarding them health insurance premiums, legal interest, and attorney's fees.
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Case Digest (G.R. No. 220481)

Facts:

  • Victor S. Limlingan and Emmanuel A. Leyco filed a complaint against the Asian Institute of Management, Inc. (AIM) for illegal suspension, non-payment of salaries, and deprivation of benefits.
  • They sought damages and attorney's fees.
  • On February 26, 2008, Labor Arbiter Napoleon M. Menese ruled in their favor, declaring the suspension illegal and ordering AIM to pay withheld salaries and benefits, plus 10% for attorney's fees.
  • AIM was directed to expunge the suspension from their records.
  • AIM appealed, and on July 4, 2008, the National Labor Relations Commission (NLRC) modified the decision, validating a six-month suspension and awarding half-year salaries and P50,000 each as nominal damages.
  • Both parties' motions for reconsideration were denied.
  • The case was elevated to the Court of Appeals, which on May 4, 2010, deleted the suspension and imposed a formal reprimand, maintaining the award of one-year salaries and P50,000 each as nominal damages.
  • The Court of Appeals' decision became final on July 25, 2011.
  • Limlingan and Leyco sought a writ of execution and recomputation of the monetary award.
  • AIM claimed to have computed and tendered payment, but no agreement was reached.
  • On November 29, 2013, the Labor Arbiter ordered AIM to pay additional amounts based on Limlingan and Leyco's computation.
  • AIM contested this, leading to further modifications by the NLRC and the Court of Appeals, particularly concerning legal interest rates and health insurance premiums.

Issue:

  • (Unlock)

Ruling:

  1. Yes, Limlingan and Leyco are entitled to interest at the rate of 12% per annum from the finality of the Court of Appeals' May 4, 2010 decision up to June 30, 2013, and 6% per annum from July 1, 2013, until full satisfaction of the award.
  2. Yes, Leyco is entitled to the award of healt...(Unlock)

Ratio:

  • The Supreme Court ruled that Limlingan and Leyco are entitled to the legal interest rates as prescribed in the Nacar v. Gallery Frames case, which stipulates 12% per annum from the finality of judgment until June 30, 2013, and 6% per annum thereafter until full satisfaction.
  • This was based on the princip...continue reading

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