G.R. No. 161110 - PAL Employees Savings and Loan Association, Inc. vs. Philippine Airlines, Inc.

PESALA is the PAL Employees Savings and Loan Association, Inc., a savings and loan association whose members are employees of Philippine Airlines, Inc. (PAL).
PESALA accepts deposits from its members and facilitates the remittance of loan repayments, capital contributions, and deposits via PAL’s payroll deductions.
PAL, along with other agencies and employee organizations, was deducting amounts from employees’ salaries; at times, excessive deductions led to a “zero-net pay” situation for some employees.

In response to the excessive payroll deductions, PAL instituted a policy in July 1997 limiting salary deductions to no more than 40% of employees’ pay, effective August 1, 1997.
PESALA objected to the implementation of this 40% cap as it affected its ability to collect the contributions and amounts due to its members.

On August 7, 1997, PESALA filed a complaint for Specific Performance, Damages, or Declaratory Relief with a Prayer for Temporary Restraining Order and Injunction against PAL and Jose C. Blanco, Officer-in-Charge of PAL’s Labor Affairs Department, at the Regional Trial Court (RTC), Pasay City, Branch 118 (Civil Case No. 97-1026).
On September 3, 1997, the RTC presiding judge issued an order enjoining PAL, Jose Blanco, and related persons from implementing the 40% deduction limit, while requiring PESALA to post a credible injunction bond of P1,000,000.00.

On October 24, 1997, a Manifestation and Motion was filed urging PAL to remit the undeducted amount of P12,262,719.02 and enforce full deductions in subsequent pay periods.
On December 18, 1997, a similar Manifestation and Motion was submitted.
On February 19, 1998, a Second Supplemental Manifestation and Motion was filed claiming deprivation of remittances totaling P44,488,760.41 from September 1997 to February 15, 1998.

On March 11, 1998, Judge Nelson B. Bayot issued an Order directing PAL and Jose Blanco to remit the sum of approximately P44,488,716.41 and to enforce full salary deductions for the pending periods.
PESALA sought execution of the March 11, 1998 Order; however, on July 2, 1998, a Motion for Execution was denied on the ground that the order was interlocutory.

Respondents (PAL officials, including Avelino L. Zapanta and Andrew L. Huang) filed a petition for certiorari before the Court of Appeals (CA) challenging the March 11, 1998 Order, alleging grave abuse of discretion.
The petition was initially dismissed in a CA Resolution dated May 14, 1999 due to technical deficiencies, but the matter continued as respondents pursued other remedies.
On January 10, 2000, PESALA initiated a Petition for Indirect Contempt against Jose Blanco, Avelino Zapanta, and Andrew Huang alleging that they deliberately disobeyed the RTC’s lawful orders.
Transferral of cases occurred after Judge Bayot’s retirement in August 2001, and Judge Pedro De Leon Gutierrez of Branch 119 subsequently consolidated cases and rendered a decision on November 6, 2002.
The Consolidated Decision ordered:

Enforcement of salary deductions as per the arrangement and the Clarificatory Order of May 19, 2000.
The conversion of the interim injunction into a permanent one.
Payment of attorney’s fees to PESALA.
Declaration of respondents’ guilt in indirect contempt with a remittance order of P44,480,716.41 within three days to avoid arrest.
Payment of court costs.

Respondents subsequently filed a Notice of Appeal and a Motion to Fix Bond on November 8–13, 2002.
PESALA, on the other hand, moved for Execution Pending Appeal based on the argument that RTC orders had already achieved finality, with the matter of garnishment and remittance becoming a subject of further litigation.
Various motions and orders followed, including the issuance of a Writ of Execution pending appeal, notices of garnishment against PAL’s depositary banks, and urgent motions by respondents seeking reconsideration of those writs.
On January 14, 2003, the CA issued a Temporary Restraining Order restraining further enforcement of the contested RTC orders while the legal controversies were being decided.

Whether filing a Petition for Certiorari in the CA was proper given that respondents had pending Motions for Reconsideration before the RTC.
Whether the exceptions to the general rule against interlocutory review applied in this case considering the urgent necessity and deprivation of due process.

Whether the respondents committed forum shopping by filing a Petition for Certiorari with the CA before the RTC had rendered a decision on their pending motions (to quash the Writ of Execution Pending Appeal and to lift the garnishment notices).
Whether the allegations of forum shopping are sustained in light of the differences in the relief prayed for in the distinct proceedings.

Whether the RTC’s issuance and subsequent execution of the Writ of Execution Pending Appeal was justified, given that the underlying RTC order was interlocutory.
The issue of whether such an order could be considered “final and executory” pursuant to the distinction between final judgments and interlocutory orders.

Whether the CA erred in applying case law (such as the pronouncements in RCBC vs. IAC and Intramuros Tennis Club, Inc. v. Philippine Tourism Authority) in a manner inconsistent with the circumstances of the present case.
Whether the trial court’s delay in addressing respondents’ motions and its alleged “peculiar interest” in a settlement affected due process and justified the respondents’ recourse to certiorari.