National Shipyards v. National Shipyards Employees
REITERATIONFacts
The Antecedents: A strike was staged by the National Shipyards Employees' and Workers' Association (union) against the National Shipyards and Steel Corporation (NASSCO) on November 5, 1956. The labor dispute was certified as involving an industry indispensable to the national interest. NASSCO filed a petition for a return-to-work order or authority to replace striking workers. Procedural History: Labor and management reached a partial settlement, including the reinstatement of union president Melanio S. Capellan and payment of his backwages. The court rendered a partial decision on July 29, 1957, enjoining compliance. The union moved for reinstatement and contempt on December 17, 1957, and January 27, 1958. The court ordered Capellan's reinstatement and backwages on November 13, 1958. However, on May 30, 1959, the court denied a contempt motion, finding NASSCO's refusal to reinstate Capellan justified due to his conviction for slight physical injuries by the Court of First Instance of Bataan (Criminal Case No. 4802), which became final in June 1959. On July 6, 1959, the court ordered NASSCO to pay Capellan's backwages up to May 30, 1959, acknowledging that while he lost the right to reinstatement, he did not lose his right to backwages. NASSCO complied. The Petition: On March 1, 1963, the President granted Capellan an absolute and unconditional pardon, restoring him to full civil and political rights. Capellan moved for reinstatement with backwages on May 7, 1963. This was denied on September 12, 1963, on the ground that the motion sought to alter an order that had become final. On December 29, 1963, the union again moved for execution of the November 13, 1958 order. On May 23, 1964, the labor court granted this motion, ordering Capellan's reinstatement with backwages from March 1, 1963, until actual reinstatement. This order was affirmed en banc on June 29, 1964. NASSCO filed the present petition for review.
Issue(s)
Whether the orders of May 30, 1959, and July 6, 1959, modified or altered the order of November 13, 1958. Whether the absolute pardon granted to Melanio Capellan restored him to the office forfeited by reason of his conviction.
Ruling
The Supreme Court affirmed the order of the Court of Industrial Relations dated May 23, 1964, and its resolution en banc dated June 29, 1964. The Court ordered the reinstatement of Melanio S. Capellan with backwages from March 1, 1963, until his actual reinstatement.
Ratio Decidendi
On the first issue: The Court held that the orders of May 30, 1959, and July 6, 1959, did not modify or alter the order of November 13, 1958. The order of May 30, 1959, specifically addressed a motion for contempt, denying it because the company's refusal to reinstate Capellan was found to be justified by his conviction. The order of July 6, 1959, dealt with the question of whether Capellan's loss of the right to reinstatement also entailed the loss of his right to backwages, which the court resolved in the negative. Therefore, the original order for reinstatement and backwages remained intact, and the subsequent orders did not change its substance. On the second issue: The Court ruled that the absolute and unconditional pardon granted to Melanio Capellan restored him to his former office. The petitioner's argument that the pardon did not restore a forfeited office was found to be based on a flawed premise. Capellan was convicted of slight physical injuries with a penalty of 20 days imprisonment (arresto menor), which carries the accessory penalty of suspension from the right to hold office during the term of the sentence, not forfeiture. Upon serving the sentence, his suspension was lifted. The pardon, therefore, acted as a reiteration of the termination of this suspension and expressly restored his political rights, which include the right to hold office. The Court distinguished this from cases involving actual forfeiture of office, citing that the pardon did not expressly provide for restoration to his former job, but rather that the conviction itself did not result in forfeiture but only suspension.
Main Doctrine
An absolute and unconditional pardon granted by the President restores an individual to full civil and political rights, including the right to hold office, even if the conviction for which the pardon was granted resulted in the suspension of the right to hold office, not forfeiture.