Naga College Foundation Education Workers Organization (NCFEWO) v. Bose
REITERATIONFacts
1. The Antecedents: Petitioners, employees of Naga College Foundation, filed a complaint for unfair labor practice, reinstatement, backwages, and damages against the Foundation and its president, alleging illegal dismissal. The private respondents, in turn, filed a complaint against the petitioners for conducting an illegal strike. The cases were consolidated. 2. Procedural History: The Executive Labor Arbiter (ELA) ordered the reinstatement of the petitioners and payment of backwages on August 20, 1992. Private respondents appealed, and while the appeal was pending, petitioners moved for execution of the reinstatement portion. The parties entered into a compromise agreement for payroll reinstatement and installment payments of accrued salaries, which the ELA approved. However, private respondents defaulted on payments. The NLRC affirmed the ELA's decision on June 15, 1993, and a subsequent petition for certiorari by private respondents was dismissed by the Supreme Court. Petitioners repeatedly filed motions for execution due to the ELA's inaction and issues with the case records being misplaced. On November 28, 1995, the ELA denied execution, citing abandonment of motions, and instead ordered separation pay in lieu of reinstatement, which petitioners contested. The ELA then treated their objection as an appeal, further delaying the proceedings. 3. The Petition: Petitioners filed an instant petition for mandamus to compel the ELA to resolve pending matters and issue a writ of execution. They argued that the ELA gravely abused his discretion in ordering separation pay instead of reinstatement, considering the final and executory nature of the original decision and the compromise agreement. They also contended that they were entitled to full backwages without deduction, citing the ruling in Bustamante v. NLRC, as the cause of action accrued after the effectivity of R.A. No. 6715. The issues presented to the Supreme Court included whether petitioners abandoned their agreement, whether the ELA abused his discretion in considering their manifestation as an appeal, and whether they were entitled to full backwages.
Issue(s)
Whether or not petitioners abandoned the agreement when they moved for the execution of the decision, and whether by doing so, the Executive Labor Arbiter could freely consider supervening events. Whether or not the Executive Labor Arbiter committed a grave abuse of discretion in considering as an appeal the manifestation of petitioners re the granting of separation pay in lieu of reinstatement and the opposition to the compliance of the private respondents. Whether petitioners are entitled to full backwages.
Ruling
The petition is granted. The orders of the public respondent Executive Labor Arbiter dated November 28, 1995 and January 5, 1996 are annulled and set aside. Private respondents are ordered to reinstate petitioners to their former positions without loss of seniority and to pay them full backwages, subject to any agreement the parties may have entered into. The public respondent is ordered to issue forthwith the corresponding writ for the execution of his decision of August 20, 1992 in accordance with this decision.
Ratio Decidendi
On Issue 1: The Court held that petitioners did not abandon the compromise agreement by moving for execution. The subject of both the compromise agreement and the motion for execution was their reinstatement as ordered by the ELA and affirmed by the NLRC. The Court found no basis to suppose that petitioners gave up their claim for reinstatement. Furthermore, the principle of "strained relations" could not be applied indiscriminately, as petitioners did not occupy managerial or confidential positions, and any strain was caused by the private respondents' failure to comply in good faith with the compromise agreement. The Court reiterated that "strained relations" cannot be applied simply because hostility is engendered by litigation, nor should it arise from a valid assertion of rights. The ELA's consideration of supervening events was deemed unwarranted. On Issue 2: The Court found it to be grave abuse of discretion for the ELA to order separation pay in lieu of reinstatement and to consider petitioners' motion for execution abandoned. The Court also found it worse for the ELA to treat petitioners' opposition to the modification of the final decision as an appeal, especially after months of inaction and following the filing of the petition for mandamus. This action was seen as an attempt to moot the pending action before the Supreme Court, making litigation endless and unjustly delaying the execution of a final and executory judgment. The ELA's modification of the final decision was unjustified. On Issue 3: The Court affirmed that petitioners are entitled to full backwages without deduction. While the Ferrer v. NLRC doctrine, which allowed deduction of interim earnings, was the prevailing rule at the time the ELA's decision was rendered, the Court applied the subsequent ruling in Bustamante v. NLRC. This later ruling gave full effect to R.A. No. 6715, entitling illegally dismissed employees to full backwages without deduction or qualification if the cause of action accrued after March 21, 1989. The Court rejected the argument that the "law of the case" doctrine required application of the Ferrer rule, stating that the ELA's decision awarding backwages without qualification had already become final and executory, and no ruling in the case had applied the Ferrer doctrine to settle the question of backwages.
Main Doctrine
The principle of "strained relations" cannot be applied indiscriminately to deny reinstatement, especially when the employee does not occupy a managerial or confidential position, and the strain was caused by the employer's failure to comply in good faith with a compromise agreement. Furthermore, an employee's motion for execution, filed due to undue delay, does not constitute abandonment of their claims, nor does it grant the Labor Arbiter the discretion to modify a final and executory decision by awarding separation pay in lieu of reinstatement.