Association of Drugstore Employees v. Roldan
REITERATIONFacts
The Antecedents: The Association of Drugstore Employees, representing five employees of Farmacia Oro, sought the reinstatement of these employees with back pay, as ordered by the Court of Industrial Relations (CIR) on March 4, 1952. Farmacia Oro initially complied by allowing the employees back, but in lower positions. Subsequently, Farmacia Oro dismissed them again, citing the closure of two branch stores, though a motion for permission to close was still pending. Procedural History: After the CIR's decision became final, the Association filed motions for execution. A writ of execution was issued on July 31, 1952. The sheriff attempted to reinstate the employees, but they were placed in lower positions. The sheriff then garnished P5,295.24 from Farmacia Oro's account for back wages from October 31, 1951, to July 31, 1952. Farmacia Oro moved to suspend payment, arguing that the employees had other employment and that they had failed to report for duty after being notified on June 12, 1952. The Petition: The CIR, through an order dated October 21, 1952, held that the employees were entitled to back wages only until June 12, 1952, the date they were allegedly notified to report for duty but failed to do so. A motion for reconsideration was denied by the CIR en banc on January 6, 1953, with a split vote. The Association of Drugstore Employees filed the present petition for review on certiorari with the Supreme Court, assailing the CIR's order and resolution.
Issue(s)
Whether the Court of Industrial Relations (CIR) correctly modified its final and executory decision by limiting the period for back wages to June 12, 1952, despite the employees' reinstatement in lower positions and the pendency of Farmacia Oro's petition for certiorari with the Supreme Court. Whether the notice given by Farmacia Oro on June 12, 1952, to report for duty was legally sufficient to suspend the accrual of back wages, considering the circumstances.
Ruling
The Supreme Court set aside the order of October 21, 1952, and the resolution of January 6, 1953, and directed the Court of Industrial Relations to enforce its decision of March 4, 1952. Costs were against Farmacia Oro.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the CIR departed from the terms of its final and executory decision of March 4, 1952, by suspending the payment of back wages and limiting them only up to June 12, 1952. The Court emphasized that once a judgment becomes final and executory, it can no longer be modified or set aside. The fact that Farmacia Oro placed the employees in lower positions upon their attempted reinstatement on August 14, 1952, was inconsistent with its claim of intending to reinstate them as early as June 12, 1952. Furthermore, Farmacia Oro's lack of opposition to the motions for execution filed with the CIR logically controverted any legal effect of the June 12 notice and indicated the necessity of execution to restore the employees to their former positions. The Court found that the CIR's modification of the back wages period was an improper alteration of a settled judgment. On Issue 2: The Supreme Court held that even without deciding the legal sufficiency of the verbal notice given on June 12, 1952, to report for duty, such notice could not be decisive against the employees. This was due to the allegation that the employees lived in different places and provinces, making immediate compliance on June 12 impractical and unreasonable. The Court also noted that at the time of the alleged notice, the CIR's decision of March 4, 1952, was not yet final and executory, as Farmacia Oro's petition for certiorari with the Supreme Court (G.R. No. L-5744) had not been finally disposed of, with its judgment only becoming final on July 7, 1952. This circumstance further weakened the claim that the notice on June 12, 1952, should suspend the accrual of back wages.
Main Doctrine
Once a decision of the Court of Industrial Relations becomes final and executory, it must be enforced as it is, and subsequent attempts to modify its terms or suspend payment of back wages based on grounds not previously considered or litigated are improper and constitute a departure from the established judgment.