Case Digest (G.R. No. 207983)
Facts:
Wenphil Corporation v. Almer R. Abing and Anabelle M. Tuazon, G.R. No. 207983, April 07, 2014, Supreme Court Second Division, Brion, J., writing for the Court. The petition for review on certiorari under Rule 45 challenged the Court of Appeals’ (CA) August 31, 2012 decision and June 20, 2013 resolution (CA-G.R. SP No. 117366) that annulled and set aside the National Labor Relations Commission’s (NLRC) March 26, 2010 decision and September 15, 2010 resolution in NLRC CA No. 02-8233-01 (R1-08). The NLRC had affirmed the Labor Arbiter’s (LA) November 16, 2007 order finding illegal dismissal and directing payroll reinstatement/backwages for respondents; the CA disagreed with the NLRC on the period for computing backwages.Respondents filed an illegal dismissal complaint. The LA (Geobel A. Bartolabac) ruled on December 8, 2000 that the dismissals were illegal and ordered immediate reinstatement or payroll reinstatement and backwages from February 3, 2000 until reinstatement. Wenphil appealed to the NLRC; while appeal was pending the parties executed a compromise agreement on October 29, 2001 providing for payroll reinstatement and that Wenphil’s obligation to pay salaries thereafter would cease “until such time that the questioned decision of the Honorable Labor Arbiter Geobel Bartolabac is modified, amended or reversed by the Honorable National Labor Relations Commission.”
On January 30, 2002 the NLRC affirmed the LA’s finding of illegal dismissal but modified relief by awarding separation pay in lieu of reinstatement and excluded a preventive suspension period from backwages computation. Wenphil’s motion for reconsideration was denied; it sought certiorari before the CA, which on August 27, 2003 reversed the NLRC and found dismissal valid. The Supreme Court later denied respondents’ Rule 45 petition (G.R. No. 162447, December 27, 2006), making the CA ruling final and executory on February 15, 2007.
After finality of the Supreme Court decision, respondents moved for computation and issuance of writ of execution before the LA. The LA, in an order dated November 16, 2007, directed Wenphil to pay respondents backwages from February 15, 2002 to November 8, 2002 (the date the NLRC decision became final and executory). Both parties appealed to the NLRC; the NLRC, in its March 26, 2010 decision and September 15, 2010 resolution, affirmed the LA order. The CA, however, in its August 31, 2012 decision annulled the NLRC rulings and held that under precedent the e...(Pro-only)
Issues:
- Did the parties’ October 29, 2001 compromise agreement relieve Wenphil Corporation of the obligation to pay respondents’ backwages beyond the NLRC’s modification awarding separation pay?
- Whether an employer’s obligation to pay backwages pending appeal ends upon reversal by the Court of Appeals (the first higher court to reverse a labor tribunal) or only upon finality of a Supreme Court decision; and what are the correct commencement and termination d...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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