National Rice and Corn Corporation v. Henson
REITERATIONFacts
The Antecedents: The National Rice and Corn Corporation (NARIC) filed a petition to lay off employees voluntarily severing their services due to a retrenchment program and shortage of funds. A list of employees, including respondents Celso Henson and 40 others, agreed to be laid off in exchange for gratuities equivalent to one month's salary for every year of service, not exceeding 12 months. The Court of Industrial Relations (CIR) approved this agreement on September 20, 1954, with a reservation for employees who received gratuities under protest or did not receive any. Procedural History: On October 9, 1954, the CIR rendered a decision addressing the excluded employees. It noted that while most employees agreed to separation due to overmanning and lack of work, the security guards had work to do. However, they were relieved by soldiers for reasons of economy and better protection of properties, a decision made upon the directive of the President. The CIR, while acknowledging the situation, directed NARIC to re-employ the security guards when the soldiers were recalled, before hiring new ones, in accordance with a January 7, 1953 agreement on job security and non-discrimination. The CIR also directed NARIC to extend similar generosity (gratuity) to the security guards and consider them for temporary appointments. Subsequently, on August 6, 1955, the NARIC Workers Union filed a petition for reinstatement and back wages for the laid-off security guards. On July 26, 1957, the CIR ordered the reinstatement of only 18 security guards, excluding the 41 respondents herein. On February 11, 1958, Henson and 40 others filed their own petition for reinstatement, alleging NARIC's failure to re-employ them after the soldiers' withdrawal on September 27, 1955, and instead hiring new guards, in violation of the court's order. NARIC filed a motion to dismiss, which was held in abeyance. After hearing, the CIR, on January 13, 1959, ordered the reinstatement of Henson and the other respondents, finding that their receipt of gratuity was compelled by a deadline set by NARIC's board, and that NARIC violated the October 9, 1954 decision by hiring new guards instead of reinstating them. The Petition: NARIC filed a petition for review on certiorari, assailing the CIR's January 13, 1959 order and its February 3, 1959 resolution denying reconsideration, claiming the CIR erred in ordering reinstatement and back salaries.
Issue(s)
Whether the respondent Court of Industrial Relations erred in ordering the reinstatement of the respondents and payment of back salaries. Whether the petition for reinstatement was barred by prior judgment. Whether the petition for reinstatement was filed out of time.
Ruling
The Supreme Court affirmed the order and resolution of the respondent Court of Industrial Relations. The petition for review on certiorari was denied.
Ratio Decidendi
On the issue of reinstatement and back salaries: The Court held that the CIR did not err in ordering the reinstatement of the respondents and payment of back salaries. While the CIR had initially approved the lay-off of employees, including the respondents, this approval was subject to a reservation for those who received gratuities under protest or did not receive any. The CIR's subsequent decision on October 9, 1954, clarified that the security guards, unlike other employees, had work to do. Although they were temporarily relieved by soldiers for reasons of economy and protection, the CIR explicitly directed their re-employment upon the soldiers' recall, before hiring new personnel, consistent with a prior agreement on job security. NARIC's failure to re-employ the respondents after the soldiers' withdrawal constituted a violation of this directive, making the lay-off temporary and their claim for reinstatement valid. The Court emphasized that the respondents were not considered permanently laid off, unlike those separated solely due to lack of work. On the issue of being barred by prior judgment: The Court found that the petition was not barred by prior judgment. The order of September 20, 1954, which approved the lay-off, was supplementary to the decision of October 9, 1954, which specifically addressed the situation of the security guards and mandated their re-employment. The respondents' lay-off was deemed temporary, conditioned on the recall of the soldiers. Furthermore, the CIR's order of July 26, 1957, which reinstated only 18 security guards, did not bar the present petition as the respondents herein were not parties to that specific case (CIR Case No. 746-V[11]). The respondents satisfactorily established that they were not included or made parties in that earlier proceeding. On the issue of being filed out of time: The Court ruled that the petition was not filed out of time. The action was considered an enforcement of a valid and subsisting agreement and decision. The respondents' right to reinstatement arose upon the recall of the 19th BCT soldiers on September 27, 1955, and their petitions were filed on February 12 and 18, 1958. Citing Section 17 of Commonwealth Act No. 103, as amended, and the case of Katipunan Labor Union vs. Caltex (Philippines) Inc., the Court held that the petitions were filed within a reasonable time, as the dispute between the parties in the main case had not yet been terminated. The Court noted that even a five-year delay was given due course in the cited case.
Main Doctrine
The Court affirmed the order of the Court of Industrial Relations directing the reinstatement of security guards who were laid off, despite receiving gratuities, when the company failed to re-employ them after the temporary replacement soldiers were recalled, in violation of a prior agreement and court decision mandating their re-employment before hiring new personnel. The Court also held that the petitions for reinstatement were not barred by prior judgment or filed out of time, as they were actions to enforce a subsisting agreement and decision.