Arandilla v. Maguindanao Electric Cooperative
REITERATIONFacts
The Antecedents: Genaro O. Arandilla, Jr. was employed by Maguindanao Electric Cooperative, Inc. (MAGELCO) in March 1977, eventually rising to the position of General Manager. In March 1990, MAGELCO received complaints alleging that Arandilla accepted P10,000.00 from Paraoan Rice Mill for the sale of an industrial demand meter, disposed of eight drums of used transformer oil without board approval, paid for undelivered poles, and failed to comply with purchasing procedures. An investigation by an Ad Hoc Committee recommended his suspension, a recommendation later endorsed to the National Electrification Administration (NEA). Procedural History: The NEA's Administrative Committee initially recommended Arandilla's removal, but the NEA Board of Directors, considering his length of service, issued a resolution suspending him for three months. MAGELCO's Board of Directors refused to comply, asserting that NEA lacked the authority to suspend its General Manager. Arandilla filed a motion for reconsideration of the NEA resolution, which was denied. Subsequently, NEA's audits confirmed that Arandilla's actions were detrimental to MAGELCO. Following a complaint from 107 employees, MAGELCO's Board of Directors terminated Arandilla's services on July 30, 1999. Arandilla filed a complaint for illegal dismissal with the Regional Arbitration Branch No. XII, which dismissed his complaint. The National Labor Relations Commission (NLRC) reversed this decision, finding Arandilla was illegally dismissed and ordering reinstatement or separation pay. MAGELCO's Board proposed paying separation pay instead of reinstatement, citing a loss of trust. The NLRC initially ordered reinstatement but later, through subsequent resolutions, directed MAGELCO to pay separation pay in lieu of reinstatement. Arandilla appealed to the Court of Appeals, which affirmed the NLRC's decision, holding that the initial NLRC resolution had not become final and executory. The Petition: Arandilla filed a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, assailing the Court of Appeals' decision. He contends that the Court of Appeals erred in failing to recognize that the NLRC lost jurisdiction over the case when its October 31, 2000 resolution became final and executory, and in sustaining the NLRC's subsequent resolutions that directed payment of separation pay instead of reinstatement. Arandilla insists on his reinstatement as General Manager.
Issue(s)
Whether the NLRC could still modify its Resolution dated October 31, 2000, which gave respondents the option to reinstate the petitioner or pay him his separation pay. Whether the Court of Appeals erred in sustaining the questioned NLRC Resolutions directing respondents to pay petitioner his separation pay instead of reinstating him to the service.
Ruling
The petition is DENIED. The assailed Decision dated July 31, 2002 and Resolution dated January 31, 2003 of the Court of Appeals in CA-G.R. SP No. 68717 are AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the issue of whether the NLRC could modify its Resolution of October 31, 2000: The Supreme Court agreed with the Court of Appeals that the NLRC Resolution dated October 31, 2000, was not yet final and executory when the NLRC issued the challenged Resolutions. While the Resolution became final and executory as far as the respondents were concerned because they did not file a motion for reconsideration within the ten-day reglementary period, it did not attain finality concerning the petitioner. The petitioner had the right to file a motion for reconsideration, which he seasonably did. Therefore, the NLRC retained the authority to modify its previous resolution based on the petitioner's motion. On the issue of whether the Court of Appeals erred in sustaining the NLRC's modification: The Supreme Court found no error on the part of the Court of Appeals. Since the NLRC Resolution of October 31, 2000, was not yet final and executory with respect to the petitioner, the NLRC was empowered to issue subsequent resolutions modifying its earlier decision. The subsequent resolutions directing the payment of separation pay in lieu of reinstatement were a valid exercise of the NLRC's authority, especially considering the respondents' assertion of a loss of trust and confidence, which the NLRC eventually found to be a valid ground for not pursuing reinstatement. The Court affirmed the findings that the NLRC did not commit grave abuse of discretion in rendering the assailed Resolutions dated April 26 and October 11, 2001.
Main Doctrine
The NLRC Resolution dated October 31, 2000, which granted the respondents the option to reinstate the petitioner or pay separation pay, did not attain finality with respect to the petitioner when he seasonably filed a motion for clarification and reconsideration. Therefore, the NLRC could still modify its previous resolution.