CBL Transit, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents, regular employees of petitioner CBL Transit, Inc./California Bus Lines, Inc. (allegedly a single enterprise), were not given work assignments starting December 1990. They filed a complaint for illegal dismissal. Procedural History: The Labor Arbiter found petitioner guilty of illegal dismissal, ordering separation pay. The NLRC affirmed this, rejecting petitioner's bankruptcy claim and its assertion that it was a separate entity from California Bus Lines, Inc., but discharged directors/stockholders from liability. This Court dismissed petitioner's initial certiorari petition, ordering reinstatement with backwages or separation pay. To enforce this, the Labor Arbiter directed the computation of monetary awards. A dispute arose over the computation method, with petitioner failing to appear at a crucial conference. The Labor Arbiter sustained the computation by the NLRC's Research and Information Unit, ordering petitioner to deposit P782,107.30. The NLRC affirmed this order, and a subsequent motion for reconsideration was denied. The Petition: Petitioner filed a petition for certiorari, assailing the NLRC's resolutions for allegedly altering the Court's final decision by changing "CBL Transit Inc." to "CBL Transit, Inc./California Bus Lines, Inc." and for sustaining the computation of awards.
Issue(s)
Whether the NLRC committed grave abuse of discretion in altering the Court's final decision by including "California Bus Lines, Inc." as a party liable. Whether the NLRC committed grave abuse of discretion in sustaining the Labor Arbiter's order awarding backwages and separation pay amounting to P782,107.30.
Ruling
The petition is dismissed for lack of merit. The resolutions of the NLRC dated August 22, 1996, and February 27, 1997, are affirmed in toto.
Ratio Decidendi
On the issue of altering the Court's final decision and including California Bus Lines, Inc.: The Court found that the petition was a clear attempt to re-litigate issues already passed upon and definitively resolved in a previous G.R. No. 11294. In the prior resolution, this Court explicitly stated that the assertion of petitioner that it is distinct from California Bus Lines, Inc. must be disregarded, and that either way, the conclusion that petitioner is guilty of illegal dismissal would still stand. The Court emphasized that it is not a trier of facts and that the claim of distinct entities was of no moment to the finding of illegal dismissal. Therefore, the NLRC did not commit grave abuse of discretion as the issue had already been settled. On the issue of sustaining the computation of awards: The Court held that the petitioner's contention was devoid of merit. It noted that due to the unavailability of actual payrolls, the parties themselves agreed on the basis for the computation of backwages and separation pay, which was the monthly average earnings of the individual private respondents appearing on their Social Security System (SSS) forms for the years 1988, 1989, and 1990. The only difference between the parties was the method used in arriving at the correct average monthly earnings. The Court reiterated that this issue is a question of fact, the determination of which is the statutory function of the NLRC. Judicial review in labor cases does not extend beyond evaluating the sufficiency of the evidence supporting the NLRC's findings. The Court found no basis to deviate from the doctrine that the findings of fact and conclusions of the NLRC are generally accorded great weight, respect, and finality, provided they are supported by substantial evidence. The Court also pointed out that petitioner submitted itself to the jurisdiction of the NLRC's Research and Information Unit and agreed to the basis of the computation, thus, it is now estopped from questioning the jurisdiction or the computation method for the first time. The principle of estoppel applies, barring the petitioner from raising the question of jurisdiction when it failed to invoke it in the early stages of the proceedings.
Main Doctrine
A party who submits to the jurisdiction of a tribunal, such as the NLRC's Research and Information Unit for computation of awards, and agrees to the basis of such computation, is estopped from questioning the tribunal's jurisdiction or the computation method for the first time on appeal, especially when the issue is a question of fact already passed upon by the NLRC.