G.R. No. 236271 - Ro-Ann Veterinary Manufacturing, Inc. vs. Bingbing

Respondents Fernando A. Bingbing and Gilbert C. Villaseaor were employed by Ro-Ann Veterinary Manufacturing, Inc. as technical sales representatives.
Bingbing was hired in 2013 through Rafaelito Lagat, Jr., acting as the Sales Team Leader in the Bicol region, while Villaseaor began his employment as early as 2008.
Their duties included the sale and delivery of veterinary products, collection of customer payments, and remittance of such payments to the petitioner corporation.

Around March 1, 2014, several clients informed the respondents that an advisory had been issued indicating that they were no longer associated with Ro-Ann Veterinary Manufacturing, Inc.
Upon inquiry, petitioners’ team leader, petitioner Lagat, admitted that he had indeed sent those advisories on the instructions of the company.
Petitioners alleged that respondents were involved in unexplained withdrawals of company items amounting to P84,521.57, failed to remit customer payments, and were involved in moonlighting activities.
After being confronted regarding these alleged infractions, respondents stopped reporting for work.

Respondents claimed that the termination (following petitioner Lagat’s confirmation) operated as an express but allegedly illegal termination of their employment.
They submitted their grievances to the Department of Labor and Employment (DOLE) under the Single Entry Approach and subsequently filed complaints with the NLRC Arbitration Branch on October 1, 2014.
The Labor Arbiter (LA) rendered a Decision on March 27, 2015 declaring the respondents as illegally dismissed and awarded separation pay, backwages, salary differentials, 13th month pay, and attorney’s fees aggregating to a monetary sum.

Petitioners appealed the LA’s decision at the NLRC; however, the appeal was dismissed on September 30, 2015, with a modification that deleted the monetary award for respondent Bingbing due to procedural noncompliance.
Subsequent motions for reconsideration were filed by both petitioners and Bingbing, with only Bingbing’s motion being granted, effectively reinstating the LA’s decision.
Petitioners then elevated the case to the Court of Appeals (CA) via a Petition for Certiorari under Rule 65 on March 28, 2016.
While the petition for certiorari was pending, on August 8, 2016, the LA issued a Writ of Execution to enforce the payment of the judgment award alongside an additional monetary award for separation pay and backwages recomputed until the decision’s finality.
Petitioners contested this additional award by filing a separate petition under Rule XII of the 2011 NLRC Rules of Procedure, which was denied on October 28, 2016.
The enforcement led to the collection of the judgment award and the additional amount via garnishment from the petitioner corporation’s bank deposit and cash bond.

On March 21, 2017, the CA referred the case to its Philippine Mediation Center (PMC).
On June 14, 2017, respondents filed an Ex-Parte Manifestation, claiming that the mediation process was moot due to the execution of the monetary award.
The PMC terminated the mediation process on June 21, 2017, and on July 14, 2017, the CA issued a Resolution, effectively noting the case as closed and the petition for certiorari as withdrawn.
Petitioners filed a motion for reconsideration of this resolution, which was later denied by a CA Resolution dated December 21, 2017.

Respondents argued that the withdrawal of the petition for certiorari was proper because the NLRC case had been closed and settled with the payment of the judgment award, rendering the petition moot and academic.
Petitioners countered that the payment was made solely in compliance with a Writ of Execution and should not equate to a voluntary settlement of claims.
They asserted that the CA committed reversible error by allowing the enforcement proceedings to prejudice the merits of the petition for certiorari.

Whether the CA committed a reversible error by ordering the withdrawal of the petition for certiorari due to the full satisfaction of the judgment award in compliance with the Writ of Execution.

Does the payment of the judgment award, executed pursuant to the LA’s order, equate to a voluntary settlement of the claims alleged by respondents?
Is it correct to deem the petition for certiorari moot and academic solely because execution proceedings have been carried out by the NLRC?