Facts:

The case revolves around the National Power Corporation (NPC) as the petitioner and the National Labor Relations Commission (NLRC) along with Atty. Gabriel V. Manansala as respondents. The events trace back to January 11, 1966, when the National Power Corporation Employees and Workers Association (NPCEWA) initiated a strike against NPC, claiming violations of their collective bargaining agreement. This strike resulted in a series of legal disputes leading to multiple cases, which ultimately reached the NLRC and the Supreme Court. On July 9, 1973, a Supplemental Agreement was drafted to settle differences between NPC and NPCEWA, prompting both parties to jointly withdraw their pending labor cases.

However, Atty. Simplicio J. Balcos, a previous counsel for NPCEWA, contested this withdrawal, asserting it would deprive him of his attorney's fees. The Supreme Court sided with NPCEWA and NPC, upholding the validity of their combined motion to withdraw all cases in a resolution da

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Facts:

Background and Origin of the Dispute

• In January 1966, the National Power Corporation (NPC) faced a strike staged by the National Power Corporation Employees and Workers Association (NPCEWA) over an alleged violation of their collective bargaining agreement.
• The dispute led to four related cases filed before the Court of Industrial Relations (later succeeded by the NLRC).
• On 9 July 1973, both disputants negotiated a Supplemental Agreement which resolved their differences.
• Following the agreement, NPC and NPCEWA filed a joint Motion to Withdraw all pending labor cases, an action later affirmed by this Court on 1 March 1979.
• Attorney Simplicio J. Balcos, NPCEWA’s former counsel, challenged the validity of the Supplemental Agreement by opposing the joint Motion to Withdraw, contending that withdrawing the cases would deny him additional attorney’s fees.

Attorney Fee Claims and Procedural Developments

• Subsequent to the resolution of the main dispute, private respondent Atty. Gabriel V. Manansala—the retained counsel for NPCEWA during the negotiations—filed a Motion for Remittance of Attorney’s Fees on 5 September 1979.
• NPC responded on 26 September 1979 by moving to dismiss the motion on the grounds of lack of jurisdiction, improper venue, and absence of any cause of action; it argued that a check for P10,000 had already been issued and that no further funds were held in trust for NPCEWA.
• The Labor Arbiter denied the motion to dismiss on 8 November 1979, noting that the funds, including the partial claim of P10,000 (already paid) and the remaining balance, were indeed held by NPC in trust, thereby obliging NPC to remit the owed amount to Atty. Manansala.
• A writ of execution was issued on 3 December 1979 to collect the partial claim, but due to issues with the Commission on Audit, execution could not be effected immediately, leading to the levy of NPC’s deposit on 15 February 1980.

Computation of Attorney’s Fees and Subsequent Orders

• NLRC examiners, after being directed to consult all available records, computed the economic benefits accruing to NPCEWA under the Supplemental Agreement at P12,774,000. This computation included:
• Strike duration pay for 17 days for 2,000 employees.
• Yearly wage increases resulting from an upward adjustment of the pay scale.
• A signing bonus calculated on a per-employee basis.
• An additional 6% yearly adjustment.
• Based on this computation, on 14 May 1980, the Labor Arbiter approved the report and ordered NPC to deposit with the NLRC cashier the sum equivalent to 10% of the computed benefits (minus the already paid P10,000), amounting to P1,267,400.
• NPC filed corresponding appeals and comments regarding the record of funds held in trust—NPC claimed only P33,450.18 was held—while the Labor Arbiter and the NLRC maintained that the computed benefits and subsequent deductions were legally sound.

Appeals and Partial Execution Orders

• NPC appealed the Labor Arbiter’s order in several related cases (including appeals designated under G.R. Nos. L-26169, L-26178, L-31279, and L-33909), with these appeals pending before the NLRC en banc.
• On 21 May 1980, Atty. Manansala was granted a partial execution order directing NPC to remit the remaining balance held in trust (P33,450.18).
• NPC further appealed this partial execution order on 6 June 1980.
• On 10 August 1983, the NLRC, after reviewing the factual antecedents, affirmed the 21 May 1980 order on the ground that it was an incidental aspect of the final and executory order dated 14 May 1980.

Petition for Certiorari and Final Controversies

• On 16 December 1983, NPC filed a petition for certiorari challenging the NLRC’s 10 August 1983 resolution, arguing that the NLRC lacked jurisdiction to order payment of attorney fees to Atty. Manansala.
• NPC maintained that the Supreme Court’s earlier resolution only addressed the fee claim of Atty. Balcos and that Manansala’s fees, being a matter of contract between him and NPCEWA, were extraneous to the issues adjudicated.
• The Court, however, rejected NPC’s contentions by emphasizing that Atty. Manansala's claim was properly within the ambit of the NLRC’s jurisdiction as a collateral issue in the main labor dispute.
• Ultimately, the Court found merit in NPC’s argument regarding the premature nature of the NLRC’s partial execution order, thereby annulling and setting aside the 10 August 1983 resolution.

Issue:

Jurisdiction of the NLRC

• Whether the NLRC possessed the jurisdiction to order the remittance of attorney’s fees to Atty. Gabriel V. Manansala, considering the original Supreme Court resolution only explicitly provided for the remittance of fees for Atty. Balcos.
• Whether claims for attorney’s fees arising as a collateral matter from the Supplemental Agreement could properly be entertained by the NLRC given the contractual relationship between NPCEWA and its retained counsel.

Appropriateness and Timing of the Execution Order

• Whether the issuance and execution of the partial remittance order (ordering partial execution of the fee remittance) were premature, particularly in view of the pending appeal on the overall fee computation.
• Whether the NLRC should have stayed all execution orders pending final resolution of the related appeals before the NLRC en banc.

Treatment of Funds Held in Trust

• Whether NPC, acting as a trustee holding funds for NPCEWA, was legally obliged to remit the computed attorney’s fees to Atty. Manansala.
• The proper computation and allocation of funds from the trust, including deductions specified for attorney’s fees, NPCEWA’s welfare fund, and the chapter’s share.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)