General Milling Corporation-Independent Labor Union v. General Milling Corporation
REITERATIONFacts
The Antecedents: Respondent General Milling Corporation (GMC) and Petitioner General Milling Corporation-Independent Labor Union (GMC-ILU) entered into a Collective Bargaining Agreement (CBA) effective December 1, 1988, for a three-year term. On November 29, 1991, the Union submitted a draft CBA proposal for renegotiation. GMC failed to respond, leading the Union to file a complaint for unfair labor practice. The initial dismissal by the Regional Arbitration Branch-VII was reversed by the National Labor Relations Commission (NLRC), which ordered the imposition of the Union's draft CBA proposal for the remaining two years of the original CBA (December 1, 1991, to November 30, 1993). This NLRC decision was affirmed by the Court of Appeals (CA) and subsequently by the Supreme Court (SC) in G.R. No. 146728, which found GMC guilty of unfair labor practice for its bad faith and evasion of the duty to bargain collectively. Procedural History: Following the SC's decision in G.R. No. 146728, the Union sought a writ of execution to enforce claims totaling P433,786,786.36. GMC opposed, citing the existence of quitclaims, resignation, retrenchment, and separation of workers, and arguing that the SC decision only called for the execution of a CBA, not the outright computation of benefits. Executive Labor Arbiter Ortiz-Bantug limited the computation to the period December 1, 1991, to November 30, 1993, and excluded certain employees. The NLRC affirmed this order. The CA, in two separate decisions (CA-G.R. CEB-SP No. 02226 and CA-G.R. CEB-SP No. 02232), issued conflicting rulings regarding the period of effectivity of the imposed CBA, the employees covered, and the computation of benefits. These conflicting CA decisions led to the present petitions before the Supreme Court. The Petition: Petitioner Union (GMC-ILU) in G.R. No. 183122 assails the CA's decision that partially granted its petition, affirming the NLRC's computation but excluding vacation and sick leave salary differentials, employees with quitclaims, and deducting salary increases. Petitioner GMC in G.R. No. 183889 assails the CA's decision dismissing its petition and affirming the NLRC's decision in toto. Both parties seek the reversal of the conflicting CA rulings.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in affirming the computation of the NLRC and distorting the application of Article 253 of the Labor Code in the execution of the decision in G.R. No. 146728. Whether the Court of Appeals committed grave abuse of discretion in excluding employees who executed quitclaims. Whether the Court of Appeals committed grave abuse of discretion in excluding vacation and sick leave salary differentials, and deducting alleged salary increases and other benefits given by GMC. Whether the Court of Appeals committed grave abuse of discretion in referring the case to the grievance machinery for computation of benefits under the imposed CBA. Whether the decision in CA-G.R. CEB-SP No. 02226 is in direct conflict with the decision in CA-G.R. CEB-SP No. 02232 involving the same issues and parties; and whether the decisions of the Court of Appeals are contrary to law, applicable Supreme Court decisions, established facts, and violate the law of the case.
Ruling
The Supreme Court reversed and set aside the assailed decisions of the Court of Appeals. It reinstated and modified the October 27, 2005 order of Executive Labor Arbiter Violeta Ortiz-Bantug, further excluding the 234 employees who executed deeds of waiver, release, and quitclaim from the computation of benefits for the remaining term of the original CBA.
Ratio Decidendi
On the period of effectivity of the imposed CBA and computation of benefits: The Court reiterated that the imposed CBA, by virtue of Article 253 of the Labor Code, remained in force until a new CBA was concluded. However, it clarified that the execution of the January 30, 1998 NLRC decision, as affirmed by the Supreme Court in G.R. No. 146728, was specifically limited to the "remaining two years duration of the original CBA which is from December 1, 1991 to November 30, 1993." Therefore, the computation of benefits under the writ of execution was correctly limited to this period. Benefits accruing after November 30, 1993, even under the imposed CBA, were deemed beyond the scope of the judgment sought to be enforced and should be resolved through the grievance procedure. On the employees covered by the imposed CBA and the validity of quitclaims: The Court affirmed the exclusion of employees hired after November 30, 1993, daily paid rank and file employees covered by a separate CBA, and managerial/supervisory employees, as per Article II of the imposed CBA and the Executive Labor Arbiter's order. Crucially, the Court upheld the validity of the deeds of waiver, release, and quitclaim executed by 234 employees. It found that these waivers were all-inclusive, relinquishing all claims arising from their employment, and there was no proof that they were unconscionable or obtained through fraud. Thus, these 234 employees were excluded from the computation of benefits. On the exclusion of specific benefits (vacation/sick leave differentials) and deduction of salary increases: The Court affirmed the NLRC's exclusion of vacation leave salary rate differentials and sick leave salary rate differentials due to the Union's failure to present substantial evidence to prove entitlement. Similarly, the Court rejected GMC's claim for deductions of salary increases and other benefits, finding insufficient evidence. The Court reiterated the basic evidentiary rule that the burden of proof lies with the party asserting the affirmative of an issue. On referring the computation of benefits beyond the original CBA term to the Grievance Machinery: The Court found that the computation of benefits for the period after November 30, 1993, was beyond the scope of the judgment sought to be enforced. It directed that these matters, including the identity of entitled employees and the extent of benefits, should be threshed out by the parties through the grievance procedure outlined in Article XII of the imposed CBA. This process would allow for a more accurate determination considering factors like hiring, promotions, and separations. On the conflicting CA decisions and the "Law of the Case" doctrine: The Court noted the conflicting decisions from different divisions of the CA. It held that neither decision could be invoked as the "law of the case" because neither had attained finality. The Court emphasized that the doctrine of "law of the case" applies only to final and irrevocable decisions between the same parties in the same case. The Court also pointed out that the CA should have consolidated these intimately related cases to avoid such conflicting rulings.
Main Doctrine
The execution of a judgment must conform to the dispositive portion of the decision sought to be enforced. Benefits accruing after the expiration of the original CBA term, even under an imposed CBA, must be threshed out through the grievance procedure, not through a writ of execution that varies the tenor of the judgment.