Case Digest (G.R. No. 122078)
Facts:
Philippine Rabbit Bus Lines, Inc. v. National Labor Relations Commission and Procopio Evangelista, G.R. No. 122078, April 21, 1999, Supreme Court Second Division, Bellosillo, J., writing for the Court.Procopio Evangelista was employed by Philippine Rabbit Bus Lines, Inc. beginning 6 May 1962, first as a bus conductor and later as a dispatcher; the company dismissed him on 26 October 1975. Evangelista filed a complaint for illegal dismissal. On 14 April 1976, Labor Arbiter Julio F. Andres, Jr. declared the dismissal illegal and ordered reinstatement with back wages. Petitioner’s appeal to the National Labor Relations Commission (NLRC) was dismissed for late filing.
Petitioner elevated the case to the Office of the President; on 10 May 1978 Presidential Assistant for Legal Affairs Ronaldo B. Zamora found that although there was just cause for dismissal, the dismissal was illegal for failure to observe mandatory procedural requirements under the rules implementing the Labor Code, and directed reinstatement and six months’ back wages. Petitioner’s motion for reconsideration and a second motion (restricted by Executive Order No. 19, series 1966) were denied. A writ of execution directing reinstatement was issued on 17 November 1978, but petitioner did not reinstate Evangelista though it later satisfied the monetary award.
Evangelista sought enforcement repeatedly: he manifested in September 1979 that the monetary award had been satisfied but he was not reinstated; on 16 December 1985 he moved for an alias writ of execution seeking reinstatement and additional back wages from 4 September 1979 (when he presented himself for reinstatement). Petitioner opposed in January 1986, arguing dormancy after Evangelista’s seven-year inaction. On 26 August 1986 Labor Arbiter Antonio Tria Tirona issued an alias writ of execution directing reinstatement but did not grant additional back wages not found in the Office of the President’s dispositive portion.
Petitioner appealed to the NLRC; on 30 August 1988 the NLRC affirmed the Labor Arbiter’s order directing reinstatement without awarding additional back wages, and denied motions for reconsideration on 29 November 1988. On 5 April 1989 Evangelista manifested willingness to accept separation pay instead of reinstatement. Labor Arbiter Arthur L. Amansec granted his request on 16 November 1989; petitioner proposed computing separation pay at the 1975 wage, but on 10 January 1990 the Labor Arbiter ordered separation pay to be based on the minimum wage prevailing in April 1989.
Petitioner again appealed to the NLRC. On 20 July 1995 the NLRC ordered petitioner to pay Evangelista back wages from 26 April 1986 (date of the second writ of execution) up to April 1989 (when he opted for separation pay), and directed recomputation of back wages based on the statutory minimum wage prevailing in April 1989, with an exclusion for the period 23 August 1979 to 16 December 1985. Petitioner filed a special civil action for certiorari under Rule 65 seeking to set aside th...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion in enforcing and modifying the final decision of the Office of the President by mere motion despite the lapse of seven years?
- Was the award of separation pay and back wages from 26 April 1986 to April 1989 proper and within the NLRC’s authority?
- Can petitioner attack the finality of the Office of the President’s 10 May 1978 decision after ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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