Sta. Cecilia Sawmills v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Petitioner Sta. Cecilia Sawmills, Inc. (Company) sought to review a resolution of the Court of Industrial Relations (CIR) which affirmed an order authorizing the Company to deduct 30% of P35,263.50, due as back wages to 113 dismissed workers and members of respondent Tagkawayan Labor Union (PLUM), for attorney's fees of Atty. Vicente A. Rafael. The remaining 70% was to be deposited with the CIR. Procedural History: Following a Supreme Court decision ordering the Company to pay three months' back wages to 113 dismissed workers, Atty. Rafael filed an urgent motion for execution. The parties agreed that only 113 workers were entitled to back wages, that the Company would compute the amount within 15 days, and that the manner of payment would be discussed further. The Company later computed the back wages to be P35,263.50. A notice of charging liens was filed by Atty. Rafael, Francisco Andres, and Salvador Purisima, claiming 30% of the sum for attorney's fees and expenses. The CIR Presiding Judge issued an order authorizing the deduction and payment to Atty. Rafael, and deposit of the balance with the CIR. A motion for reconsideration was denied by the CIR en banc. The Petition: The Company appealed, arguing that the CIR erred in issuing the order and resolution because there was no proof of service of the notice of charging liens to the Company or the laborers, and that the CIR, by ordering the deposit of the balance, effectively amended the Supreme Court's decision.
Issue(s)
Whether the Court of Industrial Relations erred in authorizing the deduction of attorney's fees from the back wages without proof of service of the notice of lien to the Company and the laborers. Whether the Court of Industrial Relations erred in ordering the deposit of the balance of the back wages with the court, thereby allegedly amending the Supreme Court's decision.
Ruling
The Supreme Court affirmed the order and resolution of the Court of Industrial Relations. The appeal was deemed manifestly devoid of merit.
Ratio Decidendi
On the alleged absence of proof of service of the notice of lien: The Court held that the Company had no authority to represent the laborers in connection with the alleged absence of proof of service of the notice of lien. This right belonged exclusively to the laborers themselves. Furthermore, the notice of lien bore the signatures of the proper officers of the PLUM, which had brought the action on behalf of the laborers. The Court also noted that a copy of the notice had been furnished to the Company's counsel, and the Company had filed a motion for reconsideration, providing it an opportunity to state its objections. The Company had no valid grounds to contest the validity of the lien or the amount claimed for attorney's fees. On the alleged amendment of the Supreme Court's decision by ordering the deposit of back wages: The Court clarified that the deposit of the amount constituted merely a part of the process of execution of the decision. Decisions do not typically specify the manner of execution, as this is governed by law, which is considered part of the decision itself. Therefore, the CIR's order for deposit was a procedural step in executing the final judgment and did not constitute an amendment.
Main Doctrine
The Court affirmed the resolution of the Court of Industrial Relations authorizing the deduction of attorney's fees from back wages, holding that the company had no authority to question the lack of proof of service of the notice of lien to the laborers, as this right belonged exclusively to the laborers themselves. Furthermore, the company had already been afforded an opportunity to raise objections through a motion for reconsideration.