Santos v. San Miguel Brewery
REITERATIONFacts
1. The Antecedents: Peter C. Santos was employed by San Miguel Brewery, Inc. as a temporary guard. He was dismissed from his position on February 3, 1955. The dispute centers on his entitlement to back wages following his reinstatement after being found to be a victim of unfair labor practices. 2. Procedural History: The Court of Industrial Relations (CIR) initially ordered San Miguel Brewery, Inc. to reinstate Santos as a regular security guard and pay him back wages. This decision was appealed, and this Court, on August 31, 1961, modified the order to reinstate Santos only as a temporary guard, affirming the rest of the decision. Upon remand, Santos sought back wages from his dismissal date until reinstatement. The CIR denied this, ruling the case closed and that Santos was not entitled to back wages. This denial led to the present appeal. 3. The Petition: This is an appeal by certiorari from the CIR's order and resolution denying petitioner Peter C. Santos back wages. The petitioner argues that the Supreme Court's prior decision, while modifying the reinstatement to a temporary guard position, affirmed the award of back wages. The respondents contend that the modification implicitly removed the entitlement to back wages. The petitioner seeks reversal of the CIR's denial and affirmation of his right to back wages.
Issue(s)
Whether the petitioner is entitled to back wages despite the modification of his reinstatement to a temporary position. Whether the Supreme Court's decision in G.R. No. L-12682, which modified the reinstatement order but affirmed the rest of the appealed decision, had become final and executory regarding the award of back wages.
Ruling
The Supreme Court reversed and set aside the order and resolution of the Court of Industrial Relations, ruling in favor of the petitioner. The Court held that the petitioner is entitled to back wages.
Ratio Decidendi
On the entitlement to back wages despite modification of reinstatement: The Court clarified that its decision in G.R. No. L-12682 modified the original CIR decision only with respect to the nature of reinstatement, changing it from 'regular security guard' to 'temporary guard.' However, the dispositive portion of that modified decision explicitly stated, "With this modification, the appealed decision and confirmatory resolution of the court a quo are hereby affirmed, without costs." This affirmation encompassed the original award of back wages. Therefore, the petitioner was indeed entitled to back wages as originally granted by the CIR. On the finality and executory nature of the Supreme Court's decision: The Court emphasized that its decision in G.R. No. L-12682 had become final and executory. Once a judgment becomes final, it can no longer be reversed or modified. The CIR's subsequent ruling that the petitioner was not entitled to back wages directly contradicted the affirmed portion of the original decision, which had attained finality. Consequently, the CIR acted erroneously in closing and terminating the case without awarding the back wages that were part of the affirmed judgment.
Main Doctrine
A modified Supreme Court decision that affirms the grant of back wages, even if the reinstatement was modified to a lower position, becomes final and executory and cannot be reversed or modified in that respect.