Case Summary (G.R. No. L-17504)
Background of Dismissal and Reinstatement
The CIR initially ruled on July 22, 1954, that PAL should reinstate the four employees—Fortunato Biangco, Hernando Guevarra, Bernardino Abarrientos, and Onofre Grino—and granted them back pay dating from their dismissal until their reinstatement. This ruling was affirmed by the Supreme Court on October 31, 1958.
Claim for Partial Execution of Back Wages
Following the finalization of the Supreme Court’s ruling, the respondent Association motioned for partial execution of the reinstatement order, requesting back wages for the period from May 5, 1950, to January 13, 1959, which totaled 8 years and 8 months. The claimed total amount to be paid was P158,485.33. PAL opposed this motion, insisting that any wages earned by the dismissed employees during their unemployment should be deducted from the owed back wages.
CIR's Initial Orders and PAL's Position
On February 12, 1959, the CIR issued an order directing the issuance of a writ of execution for the payment of back wages without deductions. PAL's subsequent motion for reconsideration was denied on May 22, 1959, prompting PAL to seek certiorari from the Supreme Court.
Issues on Wage Deductions and Legal Precedents
The central legal issue presented by PAL involved the right to deduct from back wages any earnings the employees received during their absence. PAL argued that allowing such a deduction aligned with established legal principles, as previous rulings emphasized that no party should benefit financially at the expense of another. Notably, this principle is reinforced in cases such as Macleod & Co. vs. Progressive Federation of Labor and Western Mindanao Lumber Co. vs. Mindanao Federation of Labor, which affirmed that any income received during a period of dismissal should be deducted from back wages.
Response of the Philippine Air Lines Employees Association
The respondent contended that the issue of wage deductions was moot, having not been raised during the prior proceedings, and argued that the CIR's previous decisions had definitively established the illegality of the dismissal. As such, they suggested that PAL's attempt to introduce evidence of the employees' earnings during the layoff would imply a concession of the wrongful nature of the dismissal, which the CIR had already determined.
Supreme Court's Ruling
In its decision, the Supreme Court acknowledged the need for equity in determining the employees’ actual earnings while they were dismissed. The Court noted that the extended duration between the dismissal and reinstatement emphasized th
...continue readingCase Syllabus (G.R. No. L-17504)
Case Overview
- The case involves a certiorari appeal by Philippine Air Lines, Inc. (PAL) regarding an order from the Court of Industrial Relations (CIR) concerning the execution of back wages for four dismissed employees.
- The order was issued on February 12, 1959, directing the computation and payment of back wages without deductions for income earned during the period of dismissal.
- The decision of the CIR en banc denying PAL's motion for reconsideration was made on May 22, 1959.
Background Facts
- On July 22, 1954, the CIR ordered PAL to reinstate four employees—Fortunato Biangco, Hernando Guevarra, Bernardino Abarrientos, and Onofre Grino—with back pay from the date of their dismissal on May 5, 1950, until their reinstatement.
- The employees were reinstated on January 14, 1959, and the Association sought partial execution for back wages covering 8 years and 7 months.
- The CIR ordered the payment of specific amounts owed to each employee, totaling P158,485.33, based on their respective monthly wages during the dismissal period.
Legal Contentions
- PAL contended that the back wages should be reduced by the amounts earned by the employees during their period of dismissal.
- The Association countered that PAL could not raise this issue as it should have