Philippine Veterans Bank v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Dr. Teodorico V. Molina (MOLINA), a former employee of Philippine Veterans Bank (PVB), was terminated when the bank was placed under receivership and subsequent liquidation in 1983 and 1985, respectively. He was rehired on June 15, 1985, to assist in the liquidation process. MOLINA later filed a complaint for wage differentials under Wage Orders Nos. NCR-01 and NCR-02, along with moral damages and attorney's fees, against the members of the liquidation team. The core of the dispute revolved around the correct computation of MOLINA's daily wage to determine his eligibility for the mandated wage increases. Procedural History: MOLINA filed his complaint (NLRC-NCR Case No. 05-02940-91) on May 11, 1991. The Labor Arbiter ruled in favor of MOLINA, ordering the payment of wage differentials and damages. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision on appeal, finding MOLINA to be a regular employee entitled to the wage increases. The NLRC later issued a resolution on April 7, 1997, quantifying the total award, and denied the motion for reconsideration on June 27, 1997. PVB, which had been rehabilitated, was substituted as the party respondent and subsequently filed the instant petition. The Petition: Philippine Veterans Bank filed this petition for certiorari under Rule 65 of the Rules of Court, assailing the NLRC's resolution and order. PVB argued that its substitution as respondent was improper, that MOLINA's claims should have been directed at the liquidation team as the employer during the liquidation period, and that MOLINA was estopped from claiming PVB as his employer. PVB also contended that the factor of 26.16 should have been used in computing MOLINA's daily wage, rendering him ineligible for the wage orders, and that the award for moral damages and attorney's fees was excessive and unsupported. PVB further argued that upon liquidation, it lost its juridical personality and could not be held liable. MOLINA, conversely, asserted that upon rehabilitation, PVB assumed all rights and obligations, including the NLRC award.
Issue(s)
Whether Wage Orders Nos. NCR-01 and NCR-02 are applicable to MOLINA. Whether MOLINA is entitled to moral damages and attorney's fees. Who is liable to pay MOLINA's claims.
Ruling
The Supreme Court affirmed the NLRC's resolution with modifications. The award of moral damages was deleted, and the award of attorney's fees was reduced to P1,250.12. The Court ruled that PVB is liable for MOLINA's claims.
Ratio Decidendi
On the applicability of Wage Orders Nos. NCR-01 and NCR-02 to MOLINA: The Court affirmed the findings of the Labor Arbiter and NLRC that MOLINA's basic monthly salary of P3,754.60 was within the coverage of both Wage Order No. 1 (ceiling P3,802.08) and Wage Order No. 2 (ceiling P4,319.16). The core dispute was the computation of his daily wage. The Court upheld the use of the 365-day factor, which PVB had previously used as a policy and which was considered part of the employment contract. The Court cited the National Wages Council's opinion that the 365-day factor was binding and could not be unilaterally changed by the employer without employee consent, as doing so would diminish benefits, prohibited by Article 100 of the Labor Code. This factor resulted in a higher monthly salary calculation, confirming MOLINA's entitlement to the wage increases. On MOLINA's entitlement to moral damages and attorney's fees: The Court agreed that MOLINA was entitled to attorney's fees, noting that while not explicitly stated in the complaint, it was prayed for in his position paper, which was deemed sufficient. However, the Court found that the NLRC improperly consolidated the awards for moral damages and attorney's fees. The award for attorney's fees was limited to ten percent (10%) of the recovered wages, as per Article 111 of the Labor Code, resulting in P1,250.12. Regarding moral damages, the Court deleted the award, finding that MOLINA failed to satisfactorily prove the factual basis and causal connection between PVB's actions and any alleged moral suffering, as required for such damages. On who is liable to pay MOLINA's claims: The Court ruled that PVB, the petitioner, is liable for MOLINA's claims. It explained that even when a bank is under receivership or liquidation, it retains its juridical personality, and its corporate existence is assumed by the receiver or liquidator. Crucially, upon PVB's rehabilitation under Republic Act No. 7169, it resumed its corporate activities and assumed all the rights and obligations of the receiver and liquidator. Therefore, PVB could not disclaim liability for claims that arose during the liquidation period, as the acts of the liquidators pertained to PVB itself.
Main Doctrine
Upon rehabilitation, a bank assumes the rights and obligations of its receiver and liquidator, including claims for unpaid wages, and the computation of daily wages based on a previously established 365-day factor cannot be unilaterally changed to the detriment of employees.