Evangelista v. National Labor Relations Commission
REVERSALFacts
The Antecedents: Private respondent Arturo Mendoza filed a complaint for illegal dismissal against petitioner Augusto Evangelista in April 1977. The case reached the Supreme Court, which rendered a decision in favor of private respondent on March 22, 1991, awarding three years of backwages. Procedural History: Private respondent filed a motion seeking clarification on the salary scale for computing the backwages, citing De Jesus vs. Philippine National Construction Corporation. On July 24, 1991, the First Division issued a resolution granting the motion and modifying the decretal portion to state that backwages should be based on the "current rate of wage levels." The Petition: Petitioner filed the instant motion for reconsideration, alleging denial of due process as he was not furnished a copy of the motion for clarification nor required to comment. He also disputed the computation of backwages based on current wage levels, arguing it should be based on the 1977 wage levels when the dismissal occurred.
Issue(s)
Whether petitioner was deprived of due process. Whether the award of backwages should be computed based on the current rate of wage levels or the wage levels prevailing at the time of illegal dismissal.
Ruling
The motion for reconsideration is GRANTED. The Resolution dated July 24, 1991, is SET ASIDE. The award of backwages is to be computed at the rate of the wage levels prevailing at the time of private respondent's illegal dismissal in 1977.
Ratio Decidendi
On the issue of due process: The Court found merit in petitioner's motion. Petitioner alleged that he was not furnished a copy of the motion for clarification and was not given an opportunity to comment. While the Court did not explicitly rule on the due process claim in the dispositive portion, the granting of the motion for reconsideration implies that the Court considered the petitioner's arguments, including the procedural aspect. On the computation of backwages: The Court reiterated the established rule that an unqualified award of backwages means the employee is paid at the wage rate at the time of dismissal. The Court cited Paramount Vinyl Products Corp. vs. NLRC, stating that the determination of the salary base for backwages requires an application of judicial precedents. The established rule is that illegally dismissed employees are to be paid their backwages without deduction or qualification as to wage increases or benefits received by their co-workers. The modification made by the First Division, ordering computation based on current wage levels, was contrary to this established jurisprudence. Therefore, the Court reverted to the principle that backwages should be computed based on the wage levels prevailing at the time of the illegal dismissal in 1977.
Main Doctrine
The award of backwages for illegally dismissed employees should be computed based on the wage levels prevailing at the time of illegal dismissal, not the current rate, unless otherwise qualified.