Torres v. San Miguel Corporation
REITERATIONFacts
The Antecedents: Petitioners Edmundo Y. Torres, Jr. and Manuel C. Castellano, former Regional Sales Manager and District Sales Supervisor of San Miguel Corporation (SMC), respectively, filed a complaint for illegal dismissal against SMC on March 14, 1984, believing they were constructively forced to retire. They were among the employees who retired effective April 15, 1984, pursuant to SMC's Retirement Plan. Procedural History: The Labor Arbiter dismissed the claims for lack of merit. The NLRC reversed this, ordering the reinstatement of petitioners and payment of back salaries, deducting retirement pay. The Supreme Court affirmed the NLRC decision in toto. Subsequently, petitioners filed a motion for execution, and SMC partially complied by paying the monetary awards. Petitioners then sought additional back salaries and benefits, invoking the Pioneer Texturizing Corporation case. The Executive Labor Arbiter granted this motion, ordering SMC to pay substantial sums. SMC appealed this order. The NLRC eventually set aside the Executive Labor Arbiter's orders, declaring that the complainants were not entitled to backwages. The NLRC denied petitioners' motion for reconsideration. The Court of Appeals affirmed the NLRC's decision and resolution, holding that the August 21, 1992 NLRC decision was not self-executory and that petitioners had reached retirement age, making reinstatement infeasible under SMC's valid retirement plan. The Petition: Petitioners assail the Court of Appeals' decision, arguing that the Pioneer case has a curative effect and that SMC should have informed them of their reinstatement options. They claim entitlement to back salaries from September 9, 1992, until their reinstatement. They also assert they were not effectively retired and are still entitled to reinstatement.
Issue(s)
Whether the petitioners are entitled to full backwages and other benefits from September 9, 1992, until their effective reinstatement, and whether the Pioneer Texturizing Corporation case has a retroactive or curative effect that would entitle petitioners to the reliefs sought. Whether the petitioners are still entitled to reinstatement despite having reached the retirement age under SMC's retirement plan. Whether petitioners are required to refund the salaries and benefits they received pursuant to the earlier NLRC reinstatement order.
Ruling
The petition is DENIED. The Decision of the Court of Appeals is AFFIRMED with the MODIFICATION that petitioners are not required to refund the amounts received by them from respondent San Miguel Corporation on account of the reinstatement order of the National Labor Relations Commission as affirmed by the Court in its Decision dated July 23, 1998.
Ratio Decidendi
On the entitlement to full backwages and the effect of the Pioneer Texturizing Corporation case: The Court clarified that at the time the August 21, 1992 NLRC decision was promulgated, the prevailing rule required a writ of execution for reinstatement to be compelled, as established in cases like Maranaw Hotel Resort Corp. v. NLRC. The Pioneer Texturizing Corp. v. NLRC case, which declared reinstatement orders self-executory, was promulgated on October 16, 1997. While the Supreme Court's decision affirming the NLRC's reinstatement order was promulgated on July 23, 1998, and the Pioneer case was already the prevailing rule, the Court noted that the petitioners only moved for execution on August 11, 1999. The Court reiterated that Republic Act No. 6715, which made reinstatement immediately executory, has no retroactive effect and thus did not apply to the dismissal in 1984. Therefore, the claim for full backwages from September 9, 1992, based on the Pioneer case, was denied. On the entitlement to reinstatement despite reaching retirement age: The Court affirmed the Court of Appeals' ruling that reinstatement was no longer feasible. This was based on the fact that petitioners had attained the retirement age of 60 years as early as 1989 for Torres, Jr. and 1990 for Castellano. The Court acknowledged that SMC's Retirement Plan, which provides for retirement at age 60, is a valid management prerogative and binds the petitioners. Consequently, SMC should take formal steps to effect their retirement. On the requirement to refund salaries and benefits received: Applying the principle of justice and equity, the Court ruled that petitioners should not be compelled to return the salaries and benefits they received based on the NLRC's reinstatement order, which was affirmed by the Supreme Court. This ruling is consistent with the doctrine in Air Philippines Corporation v. Zamora, which held that an employee reinstated during appeal, even if the reinstatement is later reversed, is not required to reimburse received salaries.
Main Doctrine
The Court of Appeals correctly ruled that the reinstatement of petitioners was no longer feasible due to their attainment of the retirement age as provided in the company's retirement plan, which is a valid management prerogative. However, petitioners are not required to refund salaries and benefits received during the pendency of the appeal, applying the principle of justice and equity.