Case Summary (G.R. No. 178699)
Factual Antecedents
Zenaida Uy was terminated from her position as a bank teller at BPI's Escolta Branch on December 14, 1995, under claims of gross disrespect, insubordination, and absence without leave. Following her dismissal, Uy, with the assistance of the Union, filed a case for illegal dismissal against BPI. On December 31, 1997, a Voluntary Arbitrator ruled that her dismissal was illegal and ordered reinstatement along with full back wages and attorney’s fees. However, the Court of Appeals modified this decision in 1998, allowing instead a fixed amount of back wages for three years, alongside separation pay, in lieu of reinstatement. The matter escalated further as both parties appealed to the Supreme Court.
Ruling of the Voluntary Arbitrator and Court of Appeals
Upon receiving the Supreme Court’s March 31, 2005 decision, which ordered BPI to pay Uy back wages from her illegal dismissal until actual reinstatement, Uy and the Union filed a Motion for Writ of Execution to determine the amount owed. In calculating the back wages, Uy included current wage rates and benefits received during the period of her dismissal. BPI disputed this computation, asserting that Uy’s back wages should be based solely on her salary at the time of dismissal.
The Voluntary Arbitrator, in December 2005, sided with Uy’s interpretation, determining that full back wages should encapsulate all wage increases and benefits. This order prompted BPI to file a petition questioning the computation, alleging that the Voluntary Arbitrator had varied the terms of the Supreme Court order.
Court of Appeals' Amended Decision
The Court of Appeals initially issued a Temporary Restraining Order (TRO) preventing the execution of the Voluntary Arbitrator’s order. The subsequent May 24, 2006, decision recognized BPI's appeal as appropriate. However, it reversed the Voluntary Arbitrator's comprehensive wage computation, ordering that back wages must reflect Uy’s salary and regular allowances only as of the time of her dismissal, while further benefits granted post-dismissal should not be included.
This led to the July 4, 2007 Amended Decision, affirming the CA’s ruling that Uy’s back wages should be based on her salary at dismissal and specific benefits proven to be received before her termination.
Supreme Court's Ruling
Both parties submitted petitions to the Supreme Court for revision, which consolidated the cases. The Supreme Court, upholding the CA's stance, asserted that the March 31, 2005 decision did not reinstate the Voluntary Arbitrator’s earlier decision awarding extensive benefits. It clarified that "full back wages" referred only to wages without any deductions or considerations for subsequent increases or benefits.
The ruling emphasized the criteria that back wages should not be influenced by awards such as CBA benefits, reaffirming the legal principle that
...continue readingCase Syllabus (G.R. No. 178699)
Case Overview
- The case involves consolidated petitions for review on certiorari filed by the Bank of the Philippine Islands (BPI), BPI Employees Union-Metro Manila, and Zenaida Uy concerning the computation of back wages and other monetary awards following an illegal dismissal.
- The Supreme Court's decision dated March 31, 2005, established the rightful entitlements of Uy after her illegal dismissal, directing BPI to pay her back wages and reinstate her to her former position.
Factual Antecedents
- Zenaida Uy was terminated from her position as a bank teller at BPI's Escolta Branch on December 14, 1995, for alleged gross disrespect, insubordination, and absence without leave.
- Following her dismissal, Uy, along with the Union, filed a case for illegal dismissal, resulting in a December 31, 1997 decision from a Voluntary Arbitrator declaring her dismissal illegal, ordering her reinstatement, and awarding back wages.
- The Court of Appeals modified the arbitrator's decision, opting for separation pay instead of reinstatement and limiting back wages to three years.
Procedural History
- The Supreme Court's March 31, 2005 decision in G.R. No. 137863 granted Uy back wages from the time of her illegal dismissal until reinstatement and ordered her reinstatement to her former position.
- Following this, Uy and the Union sought a writ of execution for the payment of back wages based on current wage levels and included various allowances and benefits.
- BPI contested this computation, arguing that back wages should be based on Uy’s salary at the time of dismissal, excluding benefits not prove