Case Summary (G.R. No. 170195)
Background of the Case
On February 2, 1982, a labor complaint was filed against SGS Far East Ltd. concerning allegations of underpayment of wages and violations of labor standard laws. This complaint was logged under NLRC Case No. NCR-2-2095-82, initiated by PSSLU alongside thirteen members. A resolution was reached through a compromise agreement on August 4, 1982, affirming the regular employment status of the complainants and entailing a settlement of Fifty Thousand Pesos (₱50,000.00), which was to be paid in two installments. The labor case was subsequently dismissed.
Initial Filings and Complications
Three years later, on August 16, 1985, four members of the union filed a motion claiming that SGS had failed to honor the terms of the compromise agreement, thereby denying them work and not fulfilling their rights under applicable legal frameworks. SGS countered this motion by asserting that the jurisdiction did not rest with Labor Arbiter Emerson Tumanon regarding issues not covered by the earlier compromise agreement.
Labor Arbiter's Decision
On February 6, 1989, Labor Arbiter Tumanon ruled in favor of the four complainants, ordering the payment of ₱80,517.72 in accumulated dues and reinstatement with back wages, reflecting unjust discrimination in promotions and employment. SGS then appealed this decision to the NLRC, which had a conflicting ruling.
NLRC Decisions and Supreme Court Involvement
The NLRC reversed Labor Arbiter Tumanon’s decision on August 8, 1991, claiming lack of jurisdiction over the matter and suggesting that the complainants should pursue a new case. The complainants then sought recourse through the Supreme Court. On March 23, 1994, the Supreme Court reinstated the Labor Arbiter's decision, affirming his jurisdiction over the claims and emphasizing that the compromise agreement covered future claims stemming from its terms.
Execution of Judgment
After the Supreme Court’s decision, the case was handed to Labor Arbiter Valentin C. Reyes for execution, where a significant discrepancy arose regarding the monetary awards calculated. While the complainants calculated their award to exceed ₱4,806,052.41, SGS calculated it to be merely ₱298,552.48. On October 18, 1994, Arbiter Reyes deemed the complainants' computation as correct and issued an order for execution.
Appeal and NLRC Stance
SGS's subsequent appeal contesting the execution order was dismissed by the NLRC on December 11, 1995. The NLRC maintained that after a decision has become final, execution is a ministerial duty, denying SGS's appeal based on the established principle that an execution order can only be contested via a valid writ of injunction.
Supreme Court's Final Ruling
Challenging this dismissal, SGS filed a petition, asserting the NLRC exe
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Case Overview
- The case involves a petition for certiorari and prohibition under Rule 65 of the Rules of Court, aimed at setting aside two resolutions from the National Labor Relations Commission (NLRC) which denied the petitioners' appeal and motion for reconsideration.
- The petitioners include SGS Far East Ltd., Neil Tovey, and Ramon Go, in their respective capacities as Operations Manager and Administrative Manager.
- The respondents include the NLRC, PSSLU, and four individual members: Crisanto Ortiz, Mauricio Forbes, Jr., Arturo Gallardo, and Tony Lim.
Background of the Case
- A complaint was filed on February 2, 1982, by PSSLU and thirteen members against SGS for underpayment of wages and violation of labor standards.
- A compromise agreement was reached on August 4, 1982, affirming the employment status of the complainants as regular seasonal daily-paid employees and establishing a settlement amount of PHP 50,000 to be paid in two installments.
- The agreement stipulated that there would be no change in employment terms, compliance with labor laws, and priority hiring for the complainants for future vacancies.
Dismissal of the Original Case
- The NLRC Case No. NCR-2-2095-82 was dismissed by Labor Arbiter Raymundo Valenzuela on August 24, 1982, following the execution of the compromise agreement and the signing of a Deed of Release and Quitclaim by the complainants.
Subsequent Allegations and Complaints
- On August 16, 1985, four of the original complainants (Ortiz, Forbes, Lim, and Gallardo) filed a Manifestation and Motion alleging various violations by SGS, including denial of work, failure to comply wi