Case Digest (G.R. No. 74214)
Facts:
St. Louis College of Tuguegarao v. National Labor Relations Commission, G.R. No. 74214, August 31, 1989, First Division, Cruz, J., writing for the Court. The petitioner, St. Louis College of Tuguegarao, employed the private respondents Bernabe Avera (hired 1974) and Jose Simangan (hired 1978). In May 1979 the college filed an application to terminate their services on the ground of old age; Simangan's appointment had been for a definite period ending March 13, 1979. The case was referred to a labor arbiter because the private respondents opposed the termination.The labor arbiter's March 11, 1980 decision ordered the reinstatement of Avera with full backwages, and treated the cash deposit made for Simangan as proper separation pay. Both Simangan and the petitioner appealed to the National Labor Relations Commission (NLRC); the NLRC dismissed the petitioner's appeal for lack of oath but modified the arbiter by directing that Simangan be reinstated with full backwages. The petitioner invoked certiorari to this Court, which dismissed the petition on August 15, 1983 (entry of judgment September 21, 1983).
Execution of the NLRC decision stalled when the NLRC records were destroyed in the December 13, 1984 fire at the NLRC main office. Upon petition of the private respondents the records were reconstituted, and a July 18, 1984 decision awarded back pay to Simangan (P58,050.00) and Avera (P59,910.00) computed from 1979 to July 1984 and ordered their reinstatement. That decision again reached this Court on certiorari and was denied.
The private respondents then asked the NLRC to correct the computation, arguing that fringe benefits (sick and vacation leaves) should be included. The NLRC remanded for recomputation. The petitioner moved for reconsideration arguing that (1) fringe benefits should not be included, (2) back wages should be limited to three years, (3) computation should follow academic rather than calendar years, and (4) separation pay already withdrawn should be excluded. By decision dated December 27, 1985 the NLRC granted the motion on the last two points but denied relief on inclusion of fringe benefits and on the three-year limitation.
The petitioner filed a third petition for certiorari before this Court, alleging grave abuse of discretion by the NLRC in including fringe benefits in back-wage computations and in refus...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion by including fringe benefits (e.g., sick and vacation leave pay and regular allowances) in the computation of back wages?
- Did the NLRC commit grave abuse of discretion in not limiting the award of back wag...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)