Milleza v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Rudy M. Milleza was employed by respondent Mariwasa Manufacturing Corporation since 1969. On August 16, 1985, he was informed of his retrenchment due to the company securing a loan from the World Bank. Petitioner filed a complaint for retirement benefits. Procedural History: The parties agreed to submit the issue of retirement benefits to a conciliator. Executive Labor Arbiter Benigno L. Vivar, Jr. indorsed the request. Conciliator Jesus Sebastian submitted a report, and the parties agreed to implement Article XII of the 1979 Retirement Plan under the heading Vesting. Executive Labor Arbiter Arthur C. Amansec issued an order declaring the retrenchment lawful and ordering the respondent to pay separation pay, retirement pay under Article XII of the 1979 plan, and accrued vacation and sick leave benefits. The Socio-Economic Analyst was directed to compute the total amount due. Respondent appealed to the NLRC. The NLRC, through its Second Division, modified the decision, deleting separation pay and retaining only retirement pay under the 1979 plan, computed based on his monthly income before retrenchment. Arbiter Amansec later issued an order for the parties to comment on a computation of retirement pay at P37,620.00 and P1,967.53 for vacation and sick leave benefits. Petitioner objected, claiming entitlement to P49,680.00 under Article XII of the 1979 plan. Respondent agreed with the computation. Arbiter Amansec sustained petitioner's claim in an order directing payment of P49,680.00. Respondent appealed again to the NLRC, which set aside the order and directed payment of P37,620.00 as retirement pay and P1,967.53 for vacation and sick leave benefits, remanding the case for proper disposition. The Petition: Petitioner filed a petition for certiorari, alleging grave abuse of discretion by the NLRC in setting aside the Labor Arbiter's order based on the 1979 Retirement Plan and in rendering a decision contrary to the evidence on record regarding the computation of retirement pay.
Issue(s)
Whether the NLRC committed grave abuse of discretion in setting aside the Labor Arbiter's order regarding the computation of retirement pay. Whether the computation of retirement pay should be based on Article XII (Vesting) or Article V, Section 5 (Severance Benefit) of the 1979 Retirement Plan.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the decision of the NLRC dated October 28, 1988, which ordered the payment of P37,620.00 as retirement pay and P1,967.53 as accrued vacation and sick leave benefits.
Ratio Decidendi
On the issue of the NLRC's grave abuse of discretion: The Supreme Court held that the NLRC did not commit grave abuse of discretion in upholding its prior executory decision and setting aside the subsequent order of the labor arbiter that attempted to modify it. A final and executory decision of the NLRC cannot be modified by the labor arbiter or in a subsequent proceeding, and the factual findings of the NLRC, when supported by substantial evidence, are conclusive on the Supreme Court. On the computation of retirement pay: The Court agreed with the NLRC's interpretation that the computation should be based on Article V, Section 5 of the 1979 Retirement Plan, which provides a vesting schedule for severance benefits. The NLRC's decision dated May 29, 1987, had already established that the complainant was entitled to only one benefit, either separation pay or retirement pay, whichever was more advantageous. The petitioner's argument that Article XII (Vesting) should have been the basis was deemed an issue that should have been raised before the NLRC before its May 29, 1987 decision became final and executory.
Main Doctrine
A final and executory decision of the National Labor Relations Commission (NLRC) cannot be modified by a labor arbiter or in a subsequent proceeding. Factual findings of the NLRC, if supported by substantial evidence, are conclusive on the Supreme Court.