Philippine Land-Air-Sea Labor Union v. Cebu Portland Cement Company
REITERATIONFacts
The Antecedents: The Philippine Land-Air-Sea Labor Union (PLASLU) sought review of a decision by the Court of Industrial Relations (CIR) which granted several concessions, including wage increases and vacation/sick leave with pay. The CIR's awards were affirmed by the Supreme Court. Procedural History: Following the affirmation, PLASLU filed a motion for the CIR to order the respondent company to deposit differential salaries and wages. The CIR granted this, ordering an examiner to determine the money value of all awarded rights, benefits, and privileges. Subsequently, PLASLU filed a motion for execution, alleging a partial report indicated P413,073.62 as the determined money value. The CIR ordered the deposit of this amount. A petition for certiorari against this order was dismissed by the Supreme Court. The Petition: Upon return of the case to the CIR, the latter issued an order on May 12, 1953, modifying its previous order of August 11, 1952. The modified order reduced the deposit amount to P19,510.84, representing the money value of wage increases under Demands A and H, and excluded P393,562.78, which represented the money value of vacation and sick leave. PLASLU contended that the CIR exceeded its jurisdiction in modifying the August 11, 1952 order, which they claimed had become final and executory.
Issue(s)
Whether the Court of Industrial Relations exceeded its jurisdiction in modifying its August 11, 1952 order, which PLASLU claimed had become final and executory. Whether the money value of vacation and sick leave should be included in the execution of the award.
Ruling
The petition is denied. The Court of Industrial Relations did not exceed its jurisdiction in modifying its August 11, 1952 order. The order of August 11, 1952, was an interlocutory order and not a final judgment, and was therefore subject to modification by the CIR under its inherent powers to conform to law and justice. The money value of vacation and sick leave was correctly excluded from the execution of the award as it was not covered by the original decision and the examiner's report had erroneously included it.
Ratio Decidendi
On the issue of whether the CIR exceeded its jurisdiction in modifying its August 11, 1952 order: The Supreme Court held that the order of August 11, 1952, was not a final judgment or order determinative of an issue of fact pending before the respondent court. It was merely an order for the deposit of a supposed money value based on a partial report of the court examiner. Crucially, no determination by the respondent court had been made regarding the correctness of the amounts included in the report, nor were the parties given an opportunity to contest the amounts or the right to demand payment. Therefore, it was an interlocutory order preparatory to the execution of the judgment awarding wage and salary increases. As an interlocutory order, it was subject to modification and amendment by the respondent court under its inherent powers, as provided by Section 5, Rule 124 of the Rules of Court in relation to Section 6 of Commonwealth Act No. 103. The Court reiterated the principle that any trial court discovering error or injustice in a judgment before it becomes final may correct it upon its own motion or that of the parties, without needing specific statutory authority, citing Veluz vs. Justice of the Peace of Sariaya. On the issue of whether the money value of vacation and sick leave should be included in the execution of the award: The Supreme Court found that the CIR was misled by the examiner's report and PLASLU's motion into believing that the P413,073.62 represented the money value of all awarded rights, benefits, and privileges, particularly concerning Demands A and H. However, the CIR later realized that the examiner had erroneously included matters not covered by the award, specifically the money value of vacation and sick leave under Demand F. The original order of February 21, 1952, directed the examiner to determine the money value of rights, benefits, and privileges awarded under Demands A and H, with no mention of Demand F. Furthermore, the decision itself, regarding Demand F, was limited to a recognition of the right to leave, not an order for the commutation and payment of earned leave. The respondent company had also not agreed to the commutation of such leave. Therefore, the inclusion of the money value of vacation and sick leave in the examiner's report and the subsequent order of deposit was an error. The Court emphasized that it is unfair and unjust for a party to take advantage of a mistake by court employees or the court itself to demand rights not included in the original motion for execution or the judgment sought to be implemented.
Main Doctrine
An interlocutory order, being preparatory to the execution of a judgment and not determinative of an issue of fact, is subject to modification by the court under its inherent powers to conform to law and justice, especially when it was issued based on a mistaken belief or erroneous report.