Case Summary (G.R. No. 151983-84)
Case Background
The case arises from two sets of complaints filed in 1992 and 1993 by employees from San Miguel Corporation’s Sales Offices in the provinces over issues such as illegal dismissal, underpayment of salaries, and non-payment of benefits. The complaints were consolidated into two major cases: NLRC Case No. V-0255-94 (Aguirre Cases) and NLRC Case No. V-0068-95 (Toquero Case). Labor Arbiter Reynaldo J. Gulmatico initially found the complainants in the Aguirre Cases to have been illegally dismissed and ordered reinstatement along with specific monetary awards, including attorney's fees.
NLRC Decisions
Both Aguirre and Toquero Cases were appealed to the National Labor Relations Commission (NLRC) after the complainants were unsatisfied with certain aspects of the Labor Arbiter’s decisions. The NLRC upheld the Labor Arbiter’s finding of illegal dismissal in both cases but modified the awards, including additional monetary compensation and adjusting previous amounts awarded based on various factors.
Appeal to the Court of Appeals
San Miguel Corporation subsequently appealed the NLRC’s decisions to the Court of Appeals, which affirmed the NLRC's findings but dismissed claims from complainants who executed Deeds of Release, Waiver, and Quitclaim in favor of the private respondent. The petitioner, Ortiz, represented only the remaining complainant, Alfredo Gadian Jr., who did not sign such a deed.
Petitioner’s Claims
The primary issue brought forward by Ortiz was the failure of the Court of Appeals to award attorney's fees equivalent to 10% of the monetary judgments granted by the NLRC. Ortiz claimed entitlement to these additional fees despite the signed settlements of the other complainants, asserting that these settlements were executed without his conformity.
Legal Considerations on Attorney’s Fees
The Court highlighted that attorney's fees under Article 111 of the Labor Code are typically awarded as indemnity for damages and are connected to the wages recovered by the complainants. The petitioner argued that he deserved fees based on the total awards given by the NLRC; however, the Court ruled otherwise, noting that the fees paid to Ortiz were contingent upon the amounts agreed upon in the Deeds of Release signed by the complainants.
Decision and Rationale
The Court ultimately denied Ortiz’s petition for review, stating that he w
...continue readingCase Syllabus (G.R. No. 151983-84)
Background of the Case
- This case is a Petition for Review on Certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure.
- The petitioner, Jose Max S. Ortiz, seeks to modify or partially reconsider the Decision dated August 22, 2001, and Resolution dated January 9, 2002, of the Court of Appeals in CA-G.R. SP No. 54576-77, specifically concerning the award of attorney's fees.
- The petitioner requests the Supreme Court to affirm the award of attorney's fees equivalent to 10% of the monetary awards adjudged by the National Labor Relations Commission (NLRC) in its decisions dated July 21, 1995, and July 25, 1995, related to NLRC Cases No. V-0255-94 and No. V-0068-95, respectively.
Parties Involved
- Petitioner: Jose Max S. Ortiz, a member of the Philippine Bar, represented the complainants in NLRC Cases against San Miguel Corporation.
- Respondent: San Miguel Corporation, a corporation engaged in the manufacture and sale of food and beverage products, including beer.
Summary of NLRC Cases
Aguirre Cases (NLRC Case No. V-0255-94)
- In 1992, employees from San Miguel’s Sales Offices filed complaints against the corporation for illegal dismissal and various employment-related grievances.
- The complaints included requests for reinstatement, back wages, elevation of employment status, and additional benefits under the Collective Bargaining Agreement (CBA).
- After a full trial, Labor Arbiter Reynaldo J. Gulmatico ruled on June 30, 1994, that the complainants were illegally dismissed and ordered their reinstatement and compensation, including a 10% attorney’s fee.
- The NLRC affirmed the decision on July 21, 1995, with modifications regarding sales commissions and other benefits