Case Summary (G.R. No. 156208)
Applicable Law
The pertinent legislation involves the Electric Power Industry Reform Act (EPIRA), enacted to reform the electric power industry and privatize NPC’s assets and liabilities. Additionally, separate motions filed in line with previous court decisions are considered.
Antecedent Facts
The NPB, following the provisions of EPIRA, issued resolutions aimed at terminating all NPC employees, a move later determined to be invalid due to lack of a majority vote from board members. Subsequent court decisions ruled that the terminations were illegal, asserting that the affected employees were entitled to separation benefits and back wages, to be calculated according to specific guidelines.
The Main Decision
In a previous resolution, the Court clarified that while the NPB’s resolutions regarding employee terminations were void, it did not prevent the NPB from instituting a new, legal separation program. As reinstatement of the affected employees was determined not possible due to the NPC's prior reorganization, employees were entitled to separation pay and back wages from the date of illegal termination until the point their reinstatement became impossible.
Clarification of the Main Decision
The Court maintained that previous illegal terminations had consequences for all NPC employees affected. The petitioners were thus entitled to separation pay based on years of service, along with back wages up until further legal determinations could finalize their entitlements.
NPB Ratification of Invalid Resolutions
Despite the invalidation of earlier resolutions, the NPB issued a resolution ratifying its earlier actions, complicating compliance with the Court's directive regarding employee entitlements.
Entry of Judgment
The Court's main decision and subsequent resolutions became final, necessitating the NPC and relevant parties to prepare and submit lists of terminated employees and any amounts due to them, incorporating legal interests.
Respondents' Claims and Motions
Respondents, including the NPC and Power Sector Assets and Liabilities Management Corporation (PSALM), filed motions contesting liability and compliance, as well as whether previously terminated employees had truly been compensated under the invalid resolutions.
Evaluation of Illegal Dismissal and Liabilities
The Court ultimately ruled that the NPC and PSALM were jointly liable for the judgment award, asserting that PSALM's obligations included settlement of NPC's financial liabilities concerning terminated employees, reaffirmed under EPIRA provisions.
Legal Interest Calculation and Attorney's Fees
The Court provided guidance on the computation of legal interest on awards—specifically, 12
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Case Reference
- Citation: 821 Phil. 62 EN BANC [ G.R. No. 156208, November 21, 2017]
- Parties Involved:
- Petitioners: NPC Drivers and Mechanics Association (NPC DAMA), represented by its President Roger S. San Juan, Sr.; NPC Employees & Workers Union (NEWU)- Northern Luzon, represented by its Regional President Jimmy D. Salman; and affected employees of the National Power Corporation (NPC), including Zol D. Medina, Narciso M. Magante, Vicente B. Cirio, Jr., and Necitas B. Camama.
- Respondents: The National Power Corporation (NPC), National Power Board of Directors (NPB), and several individuals including Jose Isidro N. Camacho (Chairman of the NPB) and Rolando S. Quilala (President-OIC/CEO of NPC).
Context and Background
Legislative Framework:
- The Electric Power Industry Reform Act (EPIRA) was enacted to reform the electric power industry, including the privatization of NPC's assets and liabilities.
- Established the National Power Board (NPB) with nine agency heads to oversee NPC's restructuring.
- NPB Resolution Nos. 2002-124 and 2002-125 directed the termination of all NPC employees effective January 31, 2003.
Significant Events:
- The Court ruled in a decision dated September 26, 2006, declaring the NPB resolutions void due to insufficient board voting.
- The Court clarified in subsequent resolutions that the petitioners were entitled to separation pay and back wages due to illegal dismissal.
- The NPB later ratified the invalid resolutions through Resolution No. 2007-55, which was deemed to have terminated NPC employees’ services legally.