Talisay-Silay Milling v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: On December 17, 1952, laborers of Talisay-Silay Milling Co., Inc. (Company), affiliated with Talisay-Silay Employees and Laborers Association (Union), went on strike. The Company filed a case to declare the strike illegal. Pursuant to a stipulation in February 1953, some striking laborers were reinstated. Procedural History: On June 25, 1953, the Court of Industrial Relations (CIR) declared the strike illegal but ordered the reinstatement of the remaining strikers, excluding compensation during the illegal strike. This order was affirmed by the Supreme Court in G.R. No. L-7228 on November 29, 1955. A writ of execution for reinstatement was issued on January 16, 1956, and most laborers were reinstated between January 27-30, 1956. On February 5, 1958, the Union moved for the payment of back wages from June 25, 1953, to January 30, 1956. The CIR, by order of February 10, 1958, directed a computation of back wages. An order dated April 11, 1958, amended the previous order, limiting the back wage computation period to November 10, 1953 (10 days after notice of denial of reconsideration) to January 1956. This amended order was affirmed by the Supreme Court in G.R. Nos. L-14023 and L-14135 on January 30, 1960. The Petition: On April 27, 1960, the CIR chief examiner reported the total amount due to laborers as P238,430.84. The Company objected, submitting its own computation of P68,204.10 less. On July 7, 1960, the CIR approved the examiner's report and ordered the deposit of P238,430.84 within five days. A motion for reconsideration was denied on July 26, 1960. The Company appealed by certiorari, arguing that back wages should be computed based on the employee's average pay in a given period prior to the improper discharge, citing Rothenberg on Labor Relations. The Company also prayed for a writ of preliminary injunction, which was issued upon filing a P30,000 bond.
Issue(s)
Whether the method of computing back wages used by the Court of Industrial Relations is in accordance with the Supreme Court's previous decisions. Whether the Company is entitled to have its own computation of back wages approved. Whether the writ of preliminary injunction was properly issued. Whether the Union is entitled to damages in the form of interest on the back wages.
Ruling
The Supreme Court affirmed the orders of the Court of Industrial Relations, dissolved the writ of preliminary injunction, and ordered the surety company to pay interest on the back wages. The Company was ordered to pay costs.
Ratio Decidendi
On the method of computing back wages: The Court found no merit in the Company's contention that back wages should be computed based on the employee's average pay in a given period prior to the improper discharge. The Court clarified that its previous decision in G.R. Nos. L-14023 and L-14135 did not mandate this specific method but merely quoted a statement from Rothenberg on Labor Relations regarding the National Labor Relations Board's customary practice. Crucially, the Court stated that this portion of the decision did not reject but rather sanctioned and approved the method used by the court examiner. The order directing the preparation of the report, as amended, was affirmed by the Supreme Court, thus validating the computation method. On the Company's computation: The Court explained the difference in computation methods. The CIR examiner ascertained the average daily wage of each laborer during 1951 and 1952, determined the actual number of working days from November 1953 to January 1956, and multiplied these figures. The Company, however, added compensation received in 1951-1952, divided by 24 months for average monthly earnings, and multiplied by 26.6666 months. The Court found the Company's method improper because the actual number of working days was known, and it was only fair that laborers be paid their average daily wage for those actual working days they would have worked had they been reinstated promptly. On the writ of preliminary injunction: The Court found that the Company had no jurisdiction in objecting to the method of computation and preventing the execution of the order approving the second report. The institution of an appeal does not automatically stay the execution of orders from the CIR, as per Commonwealth Act No. 113. Therefore, the writ of preliminary injunction, which prevented the members of the Union from receiving their back wages, was improperly issued and caused damages to the laborers. On the Union's counterclaim for damages (interest): The Court found the Union's counterclaim well-taken. The issuance of the writ of preliminary injunction deprived the Union members of the benefits of their back wages, while the Company retained the funds and could derive profits. Damages for delay in payment of a sum of money, in the absence of stipulation, consist of legal interest. The Court noted that the surety company did not controvert the Union's right to recover on the bond. Consequently, the surety company was sentenced to pay interest on the back wages from the date the writ of preliminary injunction was issued until full payment.
Main Doctrine
The method of computing back wages based on the employee's average daily wage during prior years, multiplied by the actual number of working days missed, is affirmed as fair and just, especially when the number of actual working days is known. The institution of an appeal does not automatically stay the execution of orders from the Court of Industrial Relations.