Special Police and Watchmen Association (Plum) Federation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners, security guards of Central Azucarera de Bais (CAB), were terminated in 1973 due to CAB's disqualification under RA 5487 from maintaining a security force for not being 100% Filipino-owned. Petitioners sued for illegal dismissal, reinstatement, illegal suspension, violation of memorandum of agreement, and backwages. Procedural History: The Secretary of Labor ordered reinstatement with six months' backwages. The Office of the President reversed this, declaring the dismissal legal but directing CAB to grant retirement or separation benefits, whichever is higher, computed up to March 31, 1974, in addition to salaries for services rendered. The case was remanded for other issues. A Report of Examiner on benefits was approved, but CAB appealed regarding the computation of 'length of service,' seeking exclusion of 'war years.' The NLRC modified the order to exclude 'war years' in the computation. This decision became final and executory. The Petition: On May 30, 1991, petitioners filed a complaint for revival of the August 4, 1976 resolution of the Office of the President, alleging refusal to recognize demands and praying for moral and exemplary damages plus attorney's fees. They later filed an amended complaint demanding legal interest and increased damages. The NLRC revived the resolution, ordering CAB to deposit the due amounts plus attorney's fees. Both parties appealed. The NLRC dismissed the complainants' appeal and partially granted CAB's appeal by deleting attorney's fees. Petitioners filed a petition for certiorari.
Issue(s)
Whether the NLRC committed grave abuse of discretion in denying the amended complaint. Whether the NLRC committed grave abuse of discretion in failing to award legal interest. Whether the NLRC committed grave abuse of discretion in refusing to consider the action for enforcement of judgment after five years as a new and independent action. Whether the NLRC committed abuse of discretion in denying the award of attorney's fees.
Ruling
The petition is dismissed for lack of merit. The NLRC did not commit grave abuse of discretion.
Ratio Decidendi
On the denial of the amended complaint: The NLRC did not err in ignoring the amended complaint because it was filed almost two years after the original complaint, long after CAB had filed its position papers, and without leave of court. The NLRC Rules of Procedure explicitly state that verified position papers shall cover only claims and causes of action raised in the complaint, and parties are not allowed to allege facts or present evidence for facts not referred to in the complaint or position papers. This rule also applies to substantial amendments that would prejudice the other party, such as the belated inclusion of claims for legal interest and increased damages. On the claim for legal interest: The claim for legal interest has no legal basis. The present suit was solely for the execution or satisfaction of a prior judgment. Furthermore, the non-satisfaction of the decision was not attributable to the respondent CAB, as there was no showing that petitioners took legal steps to have the decision implemented and that these steps were denied by CAB. Therefore, the claim for legal interest lacks legal foundation. On the action for enforcement of judgment after five years: The Court affirmed the NLRC's finding that the non-satisfaction of the judgment or the delay in its execution was not attributable to the respondent. Records showed that CAB had offered to pay, and about sixty-seven guards had opted for voluntary liquidation and were paid. Petitioners' counsel even admitted the failure of previous counsels to have the judgment enforced. Thus, the delay was not due to CAB's fault or deliberate action. On the award of attorney's fees and damages: The claim for attorney's fees and damages cannot be sustained. The respondent CAB was not at fault, nor was there any showing that it purposely delayed the payment due to the petitioners. The non-satisfaction of the judgment or the delay of its execution was not attributable to the respondent. Consequently, there is no basis for awarding moral and exemplary damages, as well as attorney's fees.
Main Doctrine
A complaint for revival of judgment must be filed within the prescriptive period allowed by law. Subsequent claims not included in the original complaint or position papers, such as claims for legal interest and increased damages, cannot be raised belatedly, especially without leave of court, as it would prejudice the other party. Claims for attorney's fees and damages are not awardable when the non-satisfaction or delay in execution of a judgment is not attributable to the respondent.