Atok-Big Wedge Mining Co. v. Castillo
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the claim of the Atok-Big Wedge Mutual Benefit Association for the payment of Christmas bonus for the year 1951 to the laborers and employees of the petitioner, Atok-Big Wedge Mining Co., Inc. The company had a history of paying Christmas bonuses from 1946 to 1950 as an act of goodwill, and financial records indicated a provision for bonus in 1951, which later disappeared from the balance sheet. The company reported a substantial net profit for 1951. 2. Procedural History: The Atok-Big Wedge Mutual Benefit Association filed a petition seeking the payment of the 1951 Christmas bonus. Initially, the Presiding Judge of the Court of Industrial Relations denied this claim. However, the respondent union filed a motion for reconsideration, which the Court of Industrial Relations, sitting en banc, granted, ordering the petitioner company to pay the Christmas bonus for 1951. The petitioner company then filed this petition for certiorari to set aside the resolution of the Court of Industrial Relations en banc or to order the reopening of the case for additional evidence. 3. The Petition: The petitioner filed a petition for certiorari under Rule 67 of the Rules of Court, arguing that the Court of Industrial Relations en banc committed grave abuse of discretion. Specifically, they contended that the en banc court erred in giving due course to the union's motion for reconsideration, in finding that the bonus was declared due and payable and set aside, in ordering the payment of the bonus, and in denying their motion for reconsideration without waiting for their arguments and without remanding the case for clarification. A key argument was that a prior stipulation between the parties agreed to submit the matter for decision by the Presiding Judge with no further appeal, which the petitioner claimed was violated by the en banc court's reconsideration.
Issue(s)
Whether the Court of Industrial Relations sitting en banc committed a grave abuse of discretion in giving due course to the respondent union's motion for reconsideration despite a stipulation that the decision of the Presiding Judge would be final. Whether the Court of Industrial Relations en banc erred in finding that the Christmas bonus for 1951 had been declared due and payable by the board of directors and that the amount of P61,227.63 had been set aside for this purpose. Whether the Court of Industrial Relations en banc erred in ordering the petitioner to pay the sum of P61,227.63 as Christmas bonus for 1951. Whether the Court of Industrial Relations en banc committed an error in not remanding the case to the trial court for clarification of inconsistencies and in denying the motion for reconsideration without waiting for the petitioner's arguments.
Ruling
The petition for certiorari is denied. The resolution of the Court of Industrial Relations en banc ordering the petitioner to pay the Christmas bonus for 1951 is affirmed.
Ratio Decidendi
On the issue of giving due course to the motion for reconsideration despite a stipulation: The Court held that the stipulation to submit the matter on stipulation with the understanding that the decision would be final was the principal agreement, and the denial of the benefit of appeal was an accessory thereto. However, when both parties elected not to submit the case on a stipulation of facts but rather to introduce evidence, this amounted to an abandonment, remission, or novation of the stipulation. Therefore, the Court of Industrial Relations sitting en banc did not commit grave abuse of discretion in giving due course to the respondent union's motion for reconsideration. Furthermore, the jurisdiction of the Court of Industrial Relations is conferred by law and cannot be taken away or modified by the parties' agreement; the proper remedy against a resolution violating such an agreement would be appeal, not certiorari. On the finding that the Christmas bonus was declared due and payable and set aside: The Court found that the findings of the Court of Industrial Relations were based on the records of the petitioner company and the testimony of its accountant. The accountant testified that the provision for bonuses no longer appeared under "reserve" because it had been declared due and payable by the board of directors and was listed under "current liabilities, accrued payroll" in the amount of P61,227.63. The accountant further clarified that "current liabilities" represent a definite obligation, unlike a "reserve" which is a provision for future contingencies. On the order to pay the Christmas bonus: The Court applied the principle laid down in Philippine Education Co. vs. Court of Industrial Relations and Union of Philippine Employees, which held that while bonus payment is not a legal obligation, the Court of Industrial Relations may make an award for the purpose of settling disputes. In the present case, the payment of the Christmas bonus was more justifiable because the petitioner had paid it for five consecutive years, regarded the amount for 1951 as a "current liability" and "part of the cost of production," and a former superintendent had indicated that the bonus would be paid and even increased. The company's accounting practices and the absence of proof to the contrary supported the conclusion that the bonus was a definite obligation. On the failure to remand the case and denial of motion for reconsideration: The Court stated that the petitioner had not asked the Court of Industrial Relations sitting en banc to remand the case for any purpose. Moreover, the court was not bound to wait for the submission of arguments in support of a pro forma motion for reconsideration. The petitioner had ample opportunity to present its arguments before the Supreme Court, and the resolution of the Court of Industrial Relations was deemed correct and should not be disturbed.
Main Doctrine
The Court of Industrial Relations, sitting en banc, did not commit grave abuse of discretion in giving due course to a motion for reconsideration of a prior order, even if there was a stipulation to submit the matter on stipulation with the understanding that the decision would be final, when the parties subsequently elected not to submit the case on a stipulation of facts but rather to introduce evidence, thereby abandoning the original stipulation. Furthermore, the Court of Industrial Relations has the power and authority to make an award for the payment of Christmas bonus based on justice and equity, especially when the company has consistently paid such bonuses in previous years, set aside an amount for it in the current year, and reported it as a current liability, despite a net profit for the year.