Case Summary (G.R. No. 111342)
Key Events Leading to the Case
In April 1987, after a deadlock in collective bargaining negotiations, the Union filed a notice of strike with the Department of Labor and Employment. In response to this, the Bank terminated the employment of the petitioners on the grounds of retrenchment, with the termination letters dated March 27, 1987, and received on April 13, 1987. Subsequently, on April 28, 1987, the petitioners filed complaints for illegal dismissal and unfair labor practices against the Bank.
Legal Proceedings Initiated
The Regional Arbitration Branch No. IX in Zamboanga City consolidated the cases filed by the petitioners and the Bank's counter-complaint for illegal strike. A decision was rendered on August 5, 1988, dismissing the Bank's complaint for illegal strike while declaring the petitioners' dismissals as illegal. The Labor Arbiter ordered their reinstatement and payment of backwages and some benefits but dismissed other claims for lack of merit.
Appeal Process
The Bank appealed the Labor Arbiter's decision on August 25, 1988, while the petitioners sought a motion for execution of the decision. The National Labor Relations Commission ("NLRC") affirmed the Labor Arbiter's decision in a resolution dated June 29, 1992. However, the petitioners then moved for reconsideration, seeking backwages from the time of the appeal until actual reinstatement.
NLRC's Rationale and Denial of Motion
The NLRC denied the petitioners' reconsideration motion on June 30, 1993, indicating that at the time the Bank appealed, the relevant amendments under R.A. No. 6715—which included provisions for posting a supersedeas bond and immediate reinstatement—had not yet taken effect.
Petitioners' Claims and Legal Basis
The petitioners argued that the NLRC had abused its discretion by limiting the award of backwages to a period of 15 months. They contended that they should be entitled to full backwages and additional compensation, inclusive of benefits, from the time their dismissal was rendered illegal until actual reinstatement.
Court's Findings and Resolution
The Court acknowledged that the amendments under R.A. No. 6715, which retroactively affected cases of illegal dismissal, were not applicable since the petitioner
...continue readingCase Syllabus (G.R. No. 111342)
Case Background
- The case involves a petition for certiorari filed by petitioners Porfirio Balladares, Jr. and Florante S. De La Pena, challenging the resolution of the National Labor Relations Commission (NLRC) dated June 30, 1993.
- Petitioners were employed by the Rural Bank of Pagadian as a driver/messenger and bank technician, respectively.
- In 1986, petitioners were elected as president and vice-president of a union formed by the bank's rank-and-file workers, known as the Philippine Integrated Industries Labor Union (Union).
- The Union entered collective bargaining negotiations with the Bank, which led to a deadlock and the Union subsequently filed a notice of strike on April 8, 1987.
Termination of Employment
- In response to the notice of strike, the Bank terminated the employment of petitioners on grounds of retrenchment, with termination letters dated March 27, 1987, received on April 13, 1987.
- Following their dismissal, petitioners filed separate complaints for illegal dismissal and unfair labor practice against the Bank on April 28, 1987.
Consolidation of Cases
- The Bank filed a counter-complaint for illegal strike against the petitioners and other employees.
- The Regional Arbitration Branch No. IX in Zamboanga City ordered the consolidation of the cases on November 10, 1987.