Philippine Apparel Workers Union v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: The Supreme Court rendered a Judgment on July 31, 1981, directing private respondent Philippine Apparel, Inc. (PAI) to pay, in addition to the increased allowance provided for in P.D. 1123, the negotiated wage increase of P0.80 daily effective April 1, 1977, and all other wage increases embodied in the collective bargaining agreement to all covered employees. This decision was immediately executory. Procedural History: A motion for reconsideration filed by PAI was denied by the Court on October 21, 1981, and entry of judgment was made on October 30, 1981. On December 18, 1981, the NLRC issued an order directing the computation of awards. Petitioner Philippine Apparel Workers Union (PAWU) filed an "Urgent Manifestation and Motion" on January 10, 1983, alleging failure by the NLRC to implement the decision despite motions for execution. PAWU prayed for the declaration of contempt against those obstructing implementation, specifically naming the president of Bagong Pilipino Philippine Apparel Workers' Union (BPPAWU) and PAI for allegedly circumventing the decision by offering P500 to members as full payment. The Petition: The NLRC explained its inability to issue a writ of execution due to the inability to determine the exact amounts due, citing missing records for certain periods. PAI had already made partial payments to some members. PAWU's counsel refused to accept PAI's offer as full payment, as it left 88 members unpaid. On October 27, 1983, the Supreme Court ordered PAI to fully comply, pay P695,413.17 with 10% attorney's fees, make payrolls available for computation, and pay remaining backwages. BPPAWU, Atty. Luis D. Flores, and PAI were adjudged guilty of contempt and ordered to pay P1,000 each.
Issue(s)
Whether the acts of the private respondent and BPPAWU in offering lesser amounts and inducing employees to sign quitclaims constitute contempt of court, and whether the quitclaims signed by employees for lesser amounts are valid and binding, precluding further claims. Whether the Supreme Court's decision of July 31, 1981, has been fully and properly implemented.
Ruling
The Court found the private respondents guilty of contempt and ordered them to pay increased penalties. The quitclaims were deemed void, and the respondent NLRC was directed to fully implement the Court's decision with modifications.
Ratio Decidendi
On the issue of contempt and the validity of quitclaims: The Court held that the attempts by BPPAWU and PAI to render the decision meaningless by paying lesser amounts and inducing employees to sign quitclaims manifested a willful disregard for the authority of the Supreme Court. The Court emphasized that a judgment that has become final and executory entitles the prevailing party to a writ of execution as a matter of right. The Court found the offer of P300.00 or P500.00 as full and final payment to be unjust, especially considering the employees' tight financial conditions. Such moves cannot be sanctioned, as they would render the award of backwages subject to the whim of the losing company, taking advantage of the rationale in Mercury Drug Co. v. CIR. Consequently, the quitclaims and releases signed by the employees were considered null and void, and the employees remained entitled to the difference between what was due and what they received. The sanctity of the contract, as interpreted by the Court, would be violated if such acts were countenanced. On the implementation of the Supreme Court's decision: The Court reiterated that the judgment had become final and executory over six years prior. The Court found the private respondents' endless belaboring of the contempt ruling to be an attempt to derail the implementation. The Court stressed that what needed to be done was the full and complete implementation of the final and executory decision. The Court enjoined the respondent NLRC to fully implement its Resolution dated October 27, 1983, with modifications regarding partial backwages, legal interest, and increased contempt penalties.
Main Doctrine
Attempts to circumvent or subvert a final and executory judgment of the Supreme Court, particularly by offering lesser amounts as full satisfaction or by inducing employees to sign quitclaims for inadequate sums, constitute contempt of court and render such quitclaims void. The prevailing party is entitled to the full execution of the judgment as a matter of right.