Case Summary (G.R. No. 112955)
Case Background
- The Aboitiz Shipping Employees Association (Petitioner) filed a complaint against Aboitiz Shipping Corporation (ASC) in 1987 for non-compliance with mandated minimum wage laws.
- The complaint cited violations of Presidential Decrees (P.D.) Nos. 1713 and 1751, as well as various Wage Orders.
- An inspection by the Department of Labor and Employment (DOLE) Regional Director led to an order for ASC to pay P1,350,828.00 for underpayment of daily allowances.
Legal Proceedings and Appeals
- ASC appealed the Regional Director's order, which was dismissed by the Secretary of Labor.
- ASC's subsequent motion for reconsideration was denied, leading to a petition for certiorari.
- The Supreme Court affirmed the Regional Director's order but excluded one complainant, Mr. Elizardo Manuel, from the award.
Execution of Judgment
- In August 1991, the Petitioner filed for an alias writ of execution, which was initially granted.
- However, this order was set aside by the Secretary of Labor, who created a Special Committee to reassess ASC's liability.
Findings of the Special Committee
- The Special Committee reduced the amount owed from P1,350,828.00 to P209,183.42, citing compliance with various wage decrees except for minor adjustments.
- The Petitioner contested this reduction, arguing it was not appealable and that the Secretary of Labor lacked jurisdiction to modify the final award.
Supreme Court Ruling
- The Court found merit in the Petitioner's claims, emphasizing that the reduction of the final judgment was unjustified.
- The basis for the modification was evidence that could have been presented earlier by ASC, thus not warranting a change in the executed order.
- The Court reiterated that a final and executory judgment cannot be altered unless new facts arise after the judgment.
Key Legal Principles
- Finality of Judgment: Once a judgment becomes final and executory, it is generally immune to alteration except in specific circumstances.
- Jurisdiction: The Secretary of Labor's authority to modify final awards is limited and cannot contravene established judgments.
Relevant Legal References
- P.D. No. 1713 and P.D. No. 1751 concerning minimum wage and living allowances.
- Previous case law, including Aboitiz Shipping Corporation v. Hon. Dionisio de la Serna, affirming the original award.
Key Takeaways
- The Supreme Court re
Case Syllabus (G.R. No. 112955)
Case Overview
- This case involves a complaint filed by the Aboitiz Shipping Employees Association (Petitioner) against Aboitiz Shipping Corporation (ASC) concerning non-compliance with mandated minimum wage laws.
- The complaint was filed in 1987 before the National Capital Region (NCR) Regional Office of the Department of Labor and Employment (DOLE).
- The complaint specifically addressed violations of Presidential Decree No. 1713, Presidential Decree No. 1751, and multiple Wage Orders.
Procedural History
- Following the filing of the complaint, an inspection of ASC's premises and employment records was conducted by the NCR Regional Director.
- The Regional Director issued an order requiring ASC to pay a total of P1,350,828.00 for underpayment of daily allowances over a specified period.
- ASC appealed the order, which was dismissed by the Secretary of Labor; subsequent motions for reconsideration by ASC were also denied.
Key Findings of the Regional Director
- The Regional Director's order mandated ASC to pay P2.00 per day in allowances from February 16, 1982, to February 15, 1985, and to continue paying the same from February 16, 1985, onwards until compliance was achieved.
- The order was affirmed by the Supreme Court after ASC's petition for certiorari.