Case Digest (G.R. No. 65882-84)
Facts:
National Power Corporation v. National Labor Relations Commission and Gabriel V. Manansala, G.R. Nos. 65882-84, April 15, 1988, Supreme Court Second Division, Padilla, J., writing for the Court.The dispute arises from a strike by members of the National Power Corporation Employees and Workers Association (NPCEWA) against National Power Corporation (NPC) in January 1966 that spawned several cases before the Court of Industrial Relations (the NLRC’s predecessor). On July 9, 1973 the parties executed a Supplemental Agreement that led them to file a joint motion to withdraw the pending labor cases; the Court later granted the joint motion in a March 1, 1979 Resolution, but remanded the matter to the Ministry of Labor (and thence to the NLRC) for determination of the reasonable attorney’s fee due to Atty. Simplicio S. Balcos, who had opposed the withdrawal.
After the remand, Atty. Gabriel V. Manansala, retained counsel for NPCEWA during negotiations leading to the Supplemental Agreement, filed on September 5, 1979 a Motion for Remittance of Attorney’s Fees seeking payment from NPC of fees claimed to be held in trust for NPCEWA. NPC moved to dismiss, asserting it had already paid P10,000 to Manansala and otherwise held no funds in trust, but the Labor Arbiter denied the motion to dismiss on November 8, 1979 and directed computation of the balance; a writ of execution for the partial P10,000 claim followed and a levy on NPC deposits occurred on February 15, 1980.
NLRC analysts reported on March 27, 1980 that the economic benefits under the Supplemental Agreement totaled P12,774,000, from which a 10% attorney’s fee yielded P1,277,400 (less the P10,000 already paid), but NPC submitted records showing it was holding only P33,450.18 in trust for NPCEWA. Despite NPC’s submission, the Labor Arbiter approved the analysts’ report and on May 14, 1980 ordered NPC to deposit P1,267,400 with the NLRC cashier; the Arbiter later granted a Notice of Partial Execution on May 21, 1980 to collect the P33,450.18 balance NPC said it held.
NPC appealed the May 14 Arbiter order to the NLRC en banc (the appeal docketed May 23, 1980 and noted in connection with related case numbers) and, after the Arbiter’s May 21 order granting partial execution, also appealed that order to the NLRC. On August 10, 1983 the NLRC en banc affirmed the May 21 order granting partial execution. NPC filed a petition for certiorari with this Court on December 16, 1983, alleging grave abuse of discretion by th...(Subscriber-Only)
Issues:
- Did the NLRC have jurisdiction to entertain and order remittance of attorney’s fees to Atty. Gabriel V. Manansala?
- Was the NLRC’s August 10, 1983 Resolution affirming the Labor Arbiter’s May 21, 1980 order granting partial execution proper while an appeal from the Arbiter’s May 14, 1980 order (fixing total attorney’s fees) was pendi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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