First Intramuros BF Condominium Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Nancy Dingayan Quimpo was employed by petitioner First Intramuros BF Condominium Corporation on February 1, 1980, and received several promotions, eventually becoming General Manager. A dispute arose when Quimpo protested her 13th-month pay calculation, asserting it should include fringe benefits as per company policy. Subsequently, her salary was reduced, which she claimed constituted a diminution of her benefits. This led to a complaint for underpayment, withholding of salary, and diminution of her 13th-month pay. Procedural History: Labor Arbiter Manuel P. Asuncion ruled in favor of Quimpo, ordering the corporation to pay her full salary, 13th-month pay for 1987, moral and exemplary damages, and attorney's fees. The First Intramuros BF Condominium Corporation appealed this decision to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter's decision and dismissed the appeal. A motion for reconsideration filed by the petitioners was also denied by the NLRC. The Petition: Petitioners First Intramuros BF Condominium Corporation and Maxy Abad filed a Petition for Certiorari with the Supreme Court, assailing the NLRC's resolutions. They argued that the NLRC acted with grave abuse of discretion in sustaining the Labor Arbiter's decision regarding the validity of salary increases, the payment of moral damages, and attorney's fees. The Supreme Court issued a temporary restraining order, which was later lifted due to the petitioners' failure to post a required bond. Subsequently, the Court gave due course to the petition. However, before a decision was rendered, both parties submitted a Joint Motion to Render Decision Based on a Compromise Agreement, wherein they agreed to settle the case amicably for P1,200,000.00.
Issue(s)
Whether the Compromise Agreement entered into by the parties during the pendency of the petition for certiorari is valid and should be approved by the Supreme Court.
Ruling
The Supreme Court approved the compromise agreement entered into by the parties and enjoined them to faithfully comply with its terms and conditions. The resolution was made immediately executory.
Ratio Decidendi
On Issue 1: The Supreme Court emphasizes that the law encourages the amicable settlement of disputes as a matter of public policy. Citing Article 2029 of the Civil Code of the Philippines, the Court notes that this encouragement is not limited to prospective litigation but extends to cases already pending in court. In the present case, the parties voluntarily negotiated a settlement totaling P1,200,000.00 to cover all claims including backwages, separation pay, damages, and attorney's fees. This agreement also encompassed G.R. No. 108830, demonstrating the parties' intent to achieve a global settlement of their labor disputes. The Court found that the terms of the settlement, including the waiver of all future claims, were consistent with legal standards and did not violate public policy. Consequently, the judicial approval of the compromise agreement serves as the final adjudication of the dispute, rendering the issues raised in the original petition for certiorari moot.
Main Doctrine
The Supreme Court approved a compromise agreement entered into by the parties in a labor dispute, finding it not contrary to law, morals, good customs, public order, and public policy, and enjoined the parties to comply with its terms.