Balladares, Jr. v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Petitioners Porfirio Balladares, Jr. and Florante de la Peña were employed by the Rural Bank of Pagadian, Inc. (the Bank). Balladares, Jr. was the president and de la Peña was the vice-president of the newly formed union of the Bank's rank-and-file employees. Following a deadlock in collective bargaining negotiations, the union filed a notice of strike. In response, the Bank terminated the employment of Balladares, Jr. and de la Peña, citing retrenchment as the reason. The termination notices were received by the petitioners after the union had filed its notice of strike. 2. Procedural History: Petitioners filed separate complaints for illegal dismissal, unfair labor practice, and various monetary claims against the Bank. The Bank, in turn, filed a complaint for illegal strike against the petitioners and other employees. The cases were consolidated, and the Acting Executive Labor Arbiter rendered a decision finding the dismissals of Balladares, Jr. and de la Peña to be illegal, ordering their reinstatement with backwages and other monetary benefits, and dismissing the Bank's complaint for illegal strike. The Bank appealed this decision to the National Labor Relations Commission (NLRC). The NLRC, in a resolution dated June 29, 1992, affirmed the Labor Arbiter's decision. Petitioners then moved for reconsideration, seeking to modify the award to include backwages from the time of appeal to actual reinstatement, arguing that the Bank's appeal was not perfected due to failure to post a supersedeas bond. The NLRC denied this motion on June 30, 1993, holding that the law requiring a bond for appeals in such cases had not yet taken effect at the time of the Bank's appeal. 3. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, assailing the NLRC's resolution denying their motion for reconsideration. They contend that the NLRC committed grave abuse of discretion in refusing to award them full backwages and in failing to act on their motion for execution pending appeal. Specifically, they argue that the Bank's appeal was not perfected due to the absence of a supersedeas bond and that they were entitled to reinstatement pending appeal under the law. The Supreme Court modified the NLRC's resolutions, granting the petition but limiting the backwages to three years from the date of illegal dismissal, as the law providing for full backwages until actual reinstatement was not retroactive.
Issue(s)
Whether petitioners are entitled to full backwages from the time their compensation was withheld up to the time of actual reinstatement. Whether petitioners are entitled to reinstatement pending appeal, considering the Bank's alleged failure to perfect its appeal due to non-posting of a supersedeas bond. Whether the NLRC committed grave abuse of discretion in denying petitioners' motion for reconsideration.
Ruling
The petition is GRANTED. The resolutions of June 29, 1992, and June 30, 1993, are MODIFIED. Private respondent is ORDERED to pay petitioners backwages for three years computed from the time of their illegal dismissal in April 1987.
Ratio Decidendi
On the entitlement to full backwages: The Court agreed that petitioners are not entitled to full backwages from the time their pay was withheld up to the time of actual reinstatement because Republic Act No. 6715, which amended Article 279 of the Labor Code to this effect, has no retroactive effect. Since the petitioners were dismissed in 1987, prior to the effectivity of RA 6715 on March 21, 1989, they cannot claim the benefits of this provision. However, the Court found that the NLRC should have awarded additional backwages. Prior to RA 6715, the established rule was that an illegally dismissed employee was entitled to an award of backwages equivalent to three years, where the case was not terminated sooner. This rule was considered to be implicitly written into the dispositive portion of decisions awarding backwages due to the difficulty in determining the exact date of actual reinstatement. Therefore, the NLRC should have modified the award to grant three years' worth of full backwages. On reinstatement pending appeal and the supersedeas bond: The Court agreed that petitioners did not have a right to reinstatement pending the resolution of the Bank's appeal. Their argument that the Bank's appeal was not perfected due to the failure to post a supersedeas bond was premised on the assumption that RA 6715 applied to their case. However, at the time the Bank filed its appeal on August 25, 1988, RA 6715, which introduced the requirement of a supersedeas bond for employer appeals involving monetary awards and provided for immediate reinstatement pending appeal, had not yet taken effect. The rule then in effect only required the payment of appeal fees and the filing of a memorandum of appeal to perfect an appeal, and upon perfection, the decision appealed from was stayed. Therefore, the Bank's appeal was validly perfected without a supersedeas bond, and the provision for reinstatement pending appeal under RA 6715 was not yet applicable. On the NLRC's denial of the motion for reconsideration: The provided text does not contain any ratio decidendi related to whether the NLRC committed grave abuse of discretion in denying the petitioners' motion for reconsideration. Therefore, there is no corresponding ratio for this issue.
Main Doctrine
While RA 6715, which mandates full backwages until actual reinstatement and requires a supersedeas bond for employer appeals, does not have retroactive effect, an illegally dismissed employee is entitled to three years' backwages prior to its effectivity, and an employer's appeal perfected before RA 6715's effectivity did not require a supersedeas bond.