Air Manila, Inc. v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the enforcement of a backwages award granted to respondent pilots of Air Manila, Inc. (AMILPA) by the Court of Industrial Relations (CIR). The initial award, determined after finding petitioner Air Manila, Inc. (AMI) guilty of unfair labor practices, was for P6,018,135.63. This Court, in a prior resolution, reduced this amount by one-third to P4,012,090.42, allowing for deductions of earnings elsewhere, to expedite satisfaction and avoid further delays. 2. Procedural History: The case has a protracted history involving multiple decisions and resolutions from the CIR and the National Labor Relations Commission (NLRC), its successor. The CIR's basic decision granting backwages was rendered on August 25, 1971, and upheld by this Court on May 8, 1972. Subsequent resolutions from the CIR in 1974 approved the computation of the award but allowed AMI to prove earnings elsewhere. AMI's attempt to have the NLRC totally reopen the computation was denied by this Court. Despite these final rulings, AMI repeatedly sought to relitigate the issues, leading to further delays in the execution of the judgment. 3. The Petition: This Court's resolution addresses the enforcement of a writ of execution issued on June 14, 1978, for the net backwages amount of P4,012,090.42. The Court denied AMI's motion for reconsideration of its June 9, 1978 resolution, finding no further reason for delay. The Court emphasized that ample time and opportunity had been given to AMI and its president, Ricardo C. Silverio, to propose a settlement, including extensions for negotiations. The denial is final and immediately executory, with the writ of execution made returnable to this Court within sixty days.
Issue(s)
Whether the Court should reconsider its Resolution of June 9, 1978, which declared the NLRC decision void and ordered the execution of the backwages award. Whether the NLRC decision of March 30, 1976, which ordered a total reopening of the backpay computation, could supersede the final and executory judgment of the CIR as upheld by the Supreme Court.
Ruling
The Court DENIED petitioner's motion for reconsideration and ordered that the writ of execution issued by the Clerk of Court be made returnable within sixty (60) days from the date of the resolution. The denial is FINAL and immediately executory.
Ratio Decidendi
On the issue of reconsideration of the Resolution of June 9, 1978: The Court found no further reason for delay in the enforcement of the writ of execution. Sufficient time and opportunity had been afforded to petitioner Air Manila, Inc. and its owner-president, Ricardo C. Silverio, to propose a method for satisfying the money judgment and to reach an amicable settlement. Several extensions were granted, but negotiations failed. The Court reiterated that in labor controversies, procedural doctrines must yield to the social justice and protection to labor provisions of the Constitution. The denial of the motion for reconsideration was deemed final and immediately executory. On the validity and effect of the NLRC decision: The Court affirmed that the NLRC decision of March 30, 1976, was null and void. This decision attempted to grant AMI the same relief already denied by the CIR and upheld by the Supreme Court, which would have led to a total reopening of the backpay award computation. Such a decision was barred by res judicata and was an attempt to overrule this Court's final judgment. The NLRC had no jurisdiction to issue such a void decision, as its authority was limited to implementing and enforcing the final award. A void decision cannot replace a valid and subsisting judgment that has become final and executory. The Court emphasized that once a judgment is final and executory, the prevailing party is entitled to a writ of execution as a matter of right, and its issuance is a ministerial duty compellable by mandamus. Inferior courts are bound by the decisions of the Supreme Court and cannot alter or modify them.
Main Doctrine
The Court denied petitioner's motion for reconsideration and ordered the enforcement of the writ of execution for the net amount of backwages, emphasizing that doctrines of a procedural character must yield to social justice and protection to labor provisions of the Constitution, and that once a judgment is final and executory, its execution is a ministerial duty compellable by mandamus.