Industrial and Transport Equipment, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Respondent Leopoldo Medrano was employed as a mechanic by petitioner Industrial and Transport Equipment Inc. (INTECO) from November 1974 until his dismissal in July 1990. After being granted an indefinite leave of absence, he secured temporary employment elsewhere. Upon reporting back to INTECO on June 18, 1990, he was confronted about his temporary job and subsequently asked to resign. On July 2, 1990, he was denied entry to the company premises, allegedly due to his termination. Procedural History: Medrano filed a complaint for illegal dismissal. The Labor Arbiter ordered INTECO to reinstate Medrano to his former position without backwages and to pay his proportionate 13th-month pay for 1990. This decision became final and executory due to INTECO's failure to appeal. Medrano's proportionate 13th-month pay was settled, but the reinstatement remained unsatisfied. Medrano then filed a motion to cite INTECO for indirect contempt and for payment of backwages. The Labor Arbiter found INTECO guilty of indirect contempt and ordered reinstatement with backwages from July 11, 1991, up to actual reinstatement. The NLRC affirmed this order in toto. The Petition: INTECO sought to set aside the NLRC decision, arguing it could not be held guilty of indirect contempt as it had reinstated Medrano on April 15, 1991, and that Medrano had abandoned his work thereafter.
Issue(s)
Whether petitioner INTECO is guilty of indirect contempt for failing to reinstate respondent Medrano. Whether the award of backwages in the contempt order is valid, considering the original decision ordered reinstatement without backwages.
Ruling
The petition is dismissed. The NLRC decision is affirmed with the modification that the award of backwages in the contempt order be deleted.
Ratio Decidendi
On the issue of indirect contempt: The Court affirmed the finding of indirect contempt against INTECO. The evidence showed that INTECO received the labor arbiter's decision on April 18, 1991, making its claim of reinstating Medrano on April 15, 1991, implausible. Furthermore, Medrano's act of filing a motion for execution of the reinstatement order on May 3, 1991, was incompatible with an intention to abandon his job. Disobedience or resistance to a lawful writ, process, order, or judgment of a court constitutes indirect contempt under Section 3(b), Rule 71 of the Rules of Civil Procedure. The labor arbiter's order for reinstatement was a lawful order, and INTECO's failure to comply constituted such disobedience. On the validity of the award of backwages in the contempt order: The Court ruled that the labor arbiter erred in awarding backwages in the contempt order. While Article 279 of the Labor Code, as amended, entitles an illegally dismissed employee to full backwages, the original decision ordering reinstatement without backwages had already become final and executory. The Court cited Asuncion vs. NLRC and Aboitiz Shipping Employees Association v. Trajano, emphasizing that once a judgment becomes final and executory, it can neither be amended nor altered, even to correct perceived errors of fact or law. Since Medrano did not appeal the original decision's inadequacy in omitting backwages, the Court was constrained to uphold the final judgment, thereby deleting the backwages awarded in the contempt order.
Main Doctrine
A party found guilty of indirect contempt for disobeying a lawful order of reinstatement may be ordered to pay backwages from the date of the order until actual reinstatement, but this award can be modified or deleted if the original decision, which became final and executory, did not include backwages and the employee failed to appeal the inadequacy of the award.