Food Terminal, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents, rank-and-file employees of petitioner Food Terminal, Inc. (FTI), a government-owned and controlled corporation, sought to recover salary differentials, traveling allowance differentials, 13th and 14th month pay, and other incremental increases. Between November 1991 and January 1992, then FTI President and General Manager Jaime S. dela Rosa issued Special Orders upgrading their positions and adjusting their salaries. Procedural History: On February 17, 1992, the FTI Board of Directors passed Board Resolution No. 0007-92, confirming minimal salary increases for rank-and-file employees and reverting promotions of officials that violated policies. FTI refused to implement the Special Orders. On March 6, 1996, private respondents filed a complaint before the Labor Arbiter. The Labor Arbiter ruled in favor of the private respondents, upholding the validity of the Special Orders and awarding differentials. Both parties appealed to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter, later allowing recomputation of monetary awards. FTI filed a Petition for Certiorari with the Court of Appeals, assailing the validity of the Special Orders, but the appellate court affirmed the NLRC. Hence, the present petition for review on certiorari. The Petition: Petitioner FTI argues that the Labor Arbiter, NLRC, and Court of Appeals erred in upholding the validity of the Special Orders, claiming Mr. dela Rosa lacked authorization and that Board Resolution No. 0007-92 revoked them. FTI also contended that only 21 of the 65 complainants had the legal personality to prosecute the case due to insufficient verification.
Issue(s)
Whether the Special Orders issued by former FTI President and General Manager Jaime S. dela Rosa upgrading the positions and salaries of private respondents are valid and binding; and whether Board Resolution No. 0007-92 nullified the Special Orders issued by Mr. dela Rosa. Whether the complaint filed by the private respondents was dismissible for lack of legal personality of some complainants due to insufficient verification.
Ruling
The petition is DENIED. The assailed Decision of the Court of Appeals affirming the Decision of the National Labor Relations Commission, which upheld the validity of the Special Orders upgrading the positions and correspondingly increasing the salaries of private respondents, and its Resolution denying reconsideration, are AFFIRMED.
Ratio Decidendi
On the validity of the Special Orders and the effect of Board Resolution No. 0007-92: The Court held that petitioner FTI failed to present any evidence to show that Mr. dela Rosa acted without or in excess of his authority when he issued the Special Orders. FTI did not enumerate the specific corporate policies allegedly contravened. Furthermore, the Court found that Board Resolution No. 0007-92 did not nullify the Special Orders for rank-and-file employees. The first paragraph of the Resolution explicitly confirmed "the minimal salary increases of rank and file employees," which squarely applied to the private respondents. The second paragraph, which dealt with officials whose promotions violated policies, was not applicable. Even if there was a defect in the issuance of the Special Orders, Board Resolution No. 0007-92 cured it by confirming the salary increases for rank-and-file employees. The appellate court, NLRC, and Labor Arbiter correctly upheld the validity of these Special Orders. On the legal personality of the complainants: The Court disagreed with FTI's contention that the complaint was dismissible for lack of legal personality of some complainants. The complaint was filed by "Complainants, by counsel," and signed by their counsel. Moreover, the verification attached to the complaint explicitly stated that the twenty-one (21) signatories were signing "for ourselves and in behalf of the abovenamed complainants." This indicated that the signatories were representing the rest of the complainants in signing the verification, which is a matter of procedure. Section 6 of the New Rules of Procedure of the NLRC presumes that an attorney appearing for a party is properly authorized. Section 7 of the same rules grants attorneys and other representatives the authority to bind their clients in matters of procedure. The signing of the verification did not diminish the claims of the other complainants, but rather safeguarded their rights, as no compromise agreement was being entered into. FTI also did not object when complainants presented evidence for their claims.
Main Doctrine
Board Resolution confirming minimal salary increases for rank-and-file employees validates prior Special Orders upgrading their positions and salaries, even if issued by a former President and General Manager, provided no evidence of lack of authority is presented. A verification signed by some complainants on behalf of others is sufficient to grant legal personality to all.