G.R. No. 212960 - Samahang Manggagawa sa General Offset Press, Inc. vs. General Offset Press, Inc.

Petitioner: Samahang Manggagawa sa General Offset Press, Inc. (SMGOPI) along with its 40 members.
Respondent: General Offset Press, Inc. (GOPI) and certain individuals connected with GOPI.
Nature of the Action: A complaint for illegal dismissal, damages, and attorney’s fees filed by SMGOPI against GOPI.

The complaints of the remaining 15 employees were dismissed with prejudice due to their settlement with GOPI.
Pending GOPI’s appeal, the complainants sought execution of the LA decision, which led to:

The issuance of a writ of execution.
The garnishment of GOPI’s account at BPI (Katipunan-Blue Ridge Branch) amounting to P79,530.26.
The deposit of the garnished funds with the NLRC Cashier.

GOPI’s initial appeal resulted in the LA decision being reversed, vacated, and set aside.
The order for reinstatement was nullified.
The NLRC declared that the unfair labor practice against GOPI was dismissed.

Notwithstanding, GOPI was ordered to pay each complainant financial assistance equivalent to one month’s salary for every year of service; this element was later deleted upon GOPI’s motion for reconsideration.
Following the CA’s affirmation of the NLRC’s findings, GOPI filed a Motion to Release regarding:

The garnished amount (P79,530.26) meant originally as compensation for the complainants’ accrued wages during the period they were supposed to have been reinstated.
Its appeal bond.

The LA, in an order dated May 4, 2011, granted the motion concerning the appeal bond and released the garnished funds to the complainants.

GOPI challenged the release of the garnished funds, arguing they should be returned to it given the subsequent reversal of the LA’s finding of illegal dismissal.
The NLRC, in its September 29, 2011 Decision, denied GOPI’s appeal for the release, holding that the complainants were still entitled to the sum representing accrued wages from January 29 to April 29, 2004.
However, upon GOPI’s subsequent motion for reconsideration, the NLRC, in its February 1, 2012 Resolution, reversed the previous decision and ordered the garnished amount to be returned to GOPI.
The complainants sought reconsideration but the NLRC, in its July 25, 2012 Resolution, denied it.
SMGOPI then elevated the matter to the Court of Appeals (CA), arguing that there was grave abuse of discretion in reversing the LA’s order favoring the complainants and releasing the garnished funds to GOPI.

The CA, in its December 19, 2013 decision and later in its May 29, 2014 Resolution denying reconsideration, upheld:

The sole issue was raised before the Supreme Court by SMGOPI on certiorari under Rule 45.

Whether the Court of Appeals erred in holding that the garnished amount should be returned to GOPI despite it originally being intended to compensate the complainants for their accrued wages pending appeal.

The complainants should be compensated for the period from January 29 to April 29, 2004 based on the LA’s original reinstatement order, which is immediately executory even pending appeal according to Article 223 (now Article 229) of the Labor Code.
Jurisprudence (specifically Islriz Trading v. Capada) supports the entitlement to accrued salaries despite reversals in other aspects of the case.

Due to GOPI’s closure (which was legally validated), reinstatement was rendered impossible and consequently, the entitlement to backwages or accrued salaries should be limited up to the date of closure.