Case Digest (G.R. No. 156208)
Facts:
In NPC Drivers and Mechanics Association (NPC DAMA) et al. v. National Power Corporation et al., G.R. No. 156208, decided June 30, 2014 under the 1987 Constitution, petitioners—unions and individual employees of the National Power Corporation (NPC)—filed on December 8, 2002 before the Supreme Court an original petition for injunction to nullify and enjoin the implementation of National Power Board (NPB) Resolutions Nos. 2002-124 and 2002-125, which directed the termination of all NPC employees effective January 31, 2003 under the restructuring mandated by Republic Act No. 9136 (EPIRA). On September 26, 2006, the Court declared these resolutions null and void, enjoined their execution, and denied NPC’s two motions for reconsideration (January 24 and June 4, 2007). Petitioners then moved for clarification, and in a September 17, 2008 Resolution the Court ruled that, as logical consequences of the nullity decision, petitioners were entitled to reinstatement or separation pay in lCase Digest (G.R. No. 156208)
Facts:
- Parties and Petition and Challenged Resolutions
- Petitioners
- NPC Drivers and Mechanics Association (NPC DAMA) represented by its President Roger S. San Juan, Sr.
- NPC Employees & Workers Union (NEWU) – Northern Luzon Regional Center represented by Jimmy D. Salman
- Individual NPC employees Zol D. Medina, Narciso M. Magante, Vicente B. Cirio, Jr., and Necitas B. Camama
- They sued in their own capacities and on behalf of all affected officers and rank-and-file employees of the National Power Corporation (NPC).
- Respondents
- National Power Corporation (NPC) and its Board of Directors (NPB) and officers
- Power Sector Assets and Liabilities Management Corporation (PSALM)
- Proceedings and Key Chronology
- NPC Board Resolutions No. 2002-124 and No. 2002-125 (Sept. 2002)
- Directed termination of all NPC personnel on January 31, 2003 under EPIRA restructuring.
- Petition for Injunction (filed Dec. 8, 2002)
- Sought to nullify and enjoin implementation of NPB Resolutions 2002-124 & 2002-125.
- Supreme Court Decision (Sept. 26, 2006)
- Declared the two NPB resolutions null and without legal effect.
- Enjoined their implementation.
- Clarification Resolution (Sept. 17, 2008)
- Held that all illegally dismissed employees are entitled to reinstatement or separation pay, backwages, wage adjustments and other benefits from Jan. 31, 2003 until reinstatement or payment.
- Approved 10% charging lien in favor of petitioners’ counsel.
- Entry of Judgment (Oct. 10, 2008) and Execution Order (Dec. 10, 2008)
- Ordered NPC officers to prepare an itemized list under oath of all separated employees and amounts due.
- Directed payment of separation benefits, backwages, interest and attorney’s charging lien.
- Compliance Difficulties and Show-Cause Orders
- NPC submitted list of only 16 executives (Mar. 2009) despite SC coverage of all employees.
- Petitioners moved to cite officers and sheriffs for contempt (Feb. 2009).
- SC issued Resolution (Dec. 2, 2009) joining PSALM, directing full list and compliance within 10 days.
- Incidental Motions and Status Quo
- NPC and PSALM filed motions for reconsideration and for T.R.O. (Dec. 2009–Jan. 2010).
- Status quo order: no garnishment pending resolution.
- Oral arguments and memoranda submitted (Jan.–Feb. 2010).
- Final Resolution (June 30, 2014)
- Resolved all pending motions, confirmed coverage, execution orders, contempt findings and PSALM’s liability.
Issues:
- Coverage of the Nullified NPB Resolutions
- Which NPC personnel—officers and rank-and-file—were separated pursuant to the nullified NPB Resolutions Nos. 2002-124 and 2002-125?
- Scope of Relief in the Clarification Resolution
- Did the September 17, 2008 Resolution grant relief not sought or contemplated in the September 26, 2006 Decision?
- Terms of the Execution Order
- Did the December 10, 2008 Resolution, which granted the petitioners’ motion for execution, exceed the terms of the September 17, 2008 Resolution?
- Effect of Subsequent NPB Resolution No. 2007-55
- What was the effect of NPB Resolution No. 2007-55 (Sept. 14, 2007) on the nullified NPB Resolutions Nos. 2002-124 and 2002-125?
- PSALM’s Liability for NPC’s Obligations
- To what extent is PSALM liable for the financial obligations of NPC arising from the separation of employees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)