Sanchez v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Petitioners were ordered to reinstate aggrieved employees and pay back wages from May 18, 1958, until compliance. The business firm, Preserver Shoe Company, ceased operations on November 2, 1963. Back pay amounting to P49,774.11 was paid to most employees, but ten individuals were excluded as their names did not appear on payrolls and time cards examined. Procedural History: The ten excluded individuals filed a motion for computation of their back wages from May 18, 1958. Petitioners opposed, arguing full compliance, that three of the ten (Beato Rendon, Eleizar Roxas, and Vicente Roxas) were convicted of crimes against them, and that others were not entitled to back wages after November 2, 1963, due to business cessation. The respondent Court of Industrial Relations (CIR) issued an order directing the Examining Division to compute back wages for seven employees from May 21, 1958, to November 2, 1963, dismissing the claims of Rendon, Eleizar Roxas, and Vicente Roxas. The CIR rejected claims for back wages after November 2, 1963, due to lack of evidence of work. The Petition: Petitioners moved for reconsideration, which was denied. The examiner computed P52,705.83 in back wages for the seven employees. Petitioners moved to set aside the report as premature and erroneous, and filed arguments supporting their motion for reconsideration. The CIR denied the motion for reconsideration. Petitioners filed a petition for review, questioning the validity of the CIR's order of September 27, 1966.
Issue(s)
Whether the CIR erred in ordering the computation of back wages, constituting a reversal of its own final orders. Whether the CIR erred in its computation of back wages, given the alleged failure of claimants to prove their right thereto. Whether the CIR erred in its computation of the number of working days and the resulting amount of back wages, deviating from the criterion used for other employees and allegedly acting arbitrarily.
Ruling
The petition is granted. The challenged order of the CIR dated September 27, 1966, and its resolution of November 3, 1966, are set aside, and the case is remanded to the CIR for disposition in accordance with the Supreme Court's opinion.
Ratio Decidendi
On the issue of whether the CIR erred in ordering the computation of back wages, constituting a reversal of its own final orders: The Court held that the CIR has broad powers to alter, modify, or set aside its awards, orders, or decisions, and to reopen any question involved, which should be liberally construed. The petitioners' contention that the CIR's order constituted a reversal of its own final orders was found to be without merit. The Court emphasized that the CIR's power to modify its decisions is comprehensive and has been interpreted with a generous scope. The principle of the law of the case does not preclude the CIR from taking further action to implement a Supreme Court decision, especially when it involves the computation of back wages. The Court noted that the CIR's initial report mentioned ten excluded workers, and the subsequent order addressed the claims of some of these individuals, which was a continuation of the implementation process rather than a reversal. On the issue of whether the CIR erred in its computation of back wages, given the alleged failure of claimants to prove their right thereto: The Court found no reversible error in the CIR's reliance on the testimony of two witnesses, Eugenia Bernabe and Adela Jacobe, despite petitioners' attempts to discredit them. The Court reiterated the doctrine that quality, not quantity, of witnesses is the primordial consideration in appraising evidence. Furthermore, the CIR is not bound by technical rules of legal evidence and is to act according to justice and equity. The Court found that the CIR's findings of fact, even if based on limited testimony, should not be disturbed unless there is a grave abuse of discretion. The Court also cited previous rulings where it was held that not all claimants need to testify personally to prove their charges. On the issue of whether the CIR erred in its computation of the number of working days and the resulting amount of back wages, deviating from the criterion used for other employees and allegedly acting arbitrarily: The Court sustained this assignment of error. It found that the CIR's computation of back wages for the seven employees, based on six days a week from May 21, 1958, to November 2, 1963, resulted in a significantly higher amount (P52,705.83) compared to the P49,774.11 paid to the original 27 workers. This disparity, coupled with the deviation from the criterion previously used and implemented in fealty to the Supreme Court's decision, indicated arbitrariness. The Court held that the CIR failed to observe the law of the case and to base its decision on substantial evidence, thereby committing a manifest failure to observe due process. The case was remanded to ensure the same basis for computation was followed as in the case of the other co-employees whose claims had already been satisfied.
Main Doctrine
The Court of Industrial Relations (CIR) has broad powers to alter, modify, or set aside its awards, orders, or decisions, and to reopen any question involved, which should be liberally construed to give full effect to its purpose and policy. However, the CIR must adhere to the law of the case, meaning its implementation of a Supreme Court decision must be in fealty to what has been decreed, and its actuations must be supported by substantial evidence to avoid arbitrariness and deprivation of due process.