Title
Panay Railways, Inc. vs. National Labor Relations Commission
Case
G.R. No. L-69416
Decision Date
Jul 11, 1985
A labor dispute over back wages led to the Supreme Court applying the three-year rule, limiting Panay Railways' liability to P36,000 for Bertie Palu-ay's reinstatement.

Case Summary (G.R. No. 146641-43)

Background of the Case

On November 7, 1963, the Labor Arbiter of Iloilo City issued a resolution ordering Panay Railways, Inc., as the successor in interest of FIVIDEC Railways, Inc., to reinstate Berty Paluay to his former position, with full back wages from his dismissal on January 1, 1977, at a monthly rate of P1,000. Since no appeal was made against this order, a writ of execution was issued at the request of Paluay. Following this, the sheriff garnished P83,000.00 from Panay Railways deposited at Traders Royal Bank.

Procedural Developments

Subsequently, Paluay filed a motion to compel Traders Royal Bank to deliver the garnished funds to the sheriff. In response, Panay Railways sought to suspend the execution of the judgment and requested a hearing to compute the due amount or to limit the back wages to three years without qualifications. On March 8, 1984, the Labor Arbiter denied this motion. The NLRC upheld this denial on appeal, and the petition escalated to the Supreme Court.

Legal Principles Invoked

The Supreme Court referenced the established principle articulated in Insular Life Assurance Co., Ltd. Employees Association v. Insular Life Assurance Co., Ltd., emphasizing that the amount of back wages awarded to employees should be fixed to a reasonable level without deductions or qualifications, limited to a maximum of three years. The rationale behind this policy is to streamline the process for awarding back wages, safeguarding against the employer's potential dilatory tactics that could deprive employees of their rightful earnings.

Conclusion and Final Ruling

The Supreme Court deter

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