Air Manila, Inc. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Respondent Air Manila Line Pilots Association (AMILPA) sought the execution of a final and executory decision dated August 25, 1971, of the Court of Industrial Relations (CIR), which declared Air Manila, Inc., et al. guilty of unfair labor practice and ordered the reinstatement of union members with backwages. The CIR's Examining Division computed the award, which was approved by the CIR on March 6, 1973, totaling P6,018,135.63, with a separate computation for by-pass pay amounting to P5,202,383.78. Procedural History: Subsequent orders from the CIR involved granting a writ of execution, dismissing a petition for relief, and a resolution allowing a limited modification to prove earnings elsewhere, payments made, and alleged errors in computation. This resolution was subject to a petition for review before the Supreme Court, which denied it for lack of merit. Despite the entry of judgment, petitioners filed a petition in the NLRC, which, on March 30, 1976, rendered a decision granting a "total reopening" of the disputed computations and remanding the case to the Labor Arbiter. AMILPA then filed a motion to compel execution of the final judgment, praying that the NLRC decision be declared a nullity and the CIR decision be executed. The Petition: The Supreme Court considered the motion to compel execution of the final judgment, noting that the NLRC decision of March 30, 1976, which ordered a "total reopening" of the approved report and computation of award, was issued without jurisdiction and was therefore null and void. The Court also addressed the issue of unreasonably delayed execution of the judgment, which had been final for over six years.
Issue(s)
Whether the NLRC decision dated March 30, 1976, which ordered a total reopening of the approved report and computation of award, is null and void. Whether the final decision of the CIR dated August 25, 1971, and subsequent resolutions upheld by the Supreme Court, should be immediately executed and implemented. Whether the Court should apply the policy of fixing backwages at a reasonable level without qualification or deduction to avoid protracted delays.
Ruling
The Court declared the NLRC decision of March 30, 1976, null and void. It directed the NLRC to expedite the determination of previous payments and alleged errors in the computation of "by-pass pay." Furthermore, the Court ordered the immediate execution of the CIR decision for backwages, overtime pay, and night differential pay in the net amount of P4,012,090.42, after deducting one-third of the total award as earnings elsewhere.
Ratio Decidendi
On the nullity of the NLRC decision: The Court held that the NLRC acted without jurisdiction when it set aside or further modified the per curiam CIR resolution of October 10, 1974, as sustained by the Supreme Court. By ordering a "total reopening" of the approved report and computation of award, instead of the limited reopening previously sanctioned, the NLRC's decision of March 30, 1976, was rendered null and void and of no force and effect. This action constituted a disregard of final and executory judgments and the established procedural hierarchy. On the execution of the CIR decision: The Court emphasized that the CIR decision, upheld by the Supreme Court, had been final and executory for over six years. The unreasonable delay was attributed to the petitioners' repeated objections and the failure of the industrial court and the NLRC to finally resolve the matter. To avoid further protracted delays and allow the members of respondent association to savor the fruits of their victory, the Court ordered the expedition of the execution, even in part, of the judgment and award in their favor. On the policy of fixing net backwages: The Court reiterated its established policy, citing precedents like Feati University Faculty Club (PAFLU) vs. Feati University, of fixing the amount of backwages at a reasonable level without qualification or deduction. This policy aims to relieve employees from proving their earnings during lay-offs and employers from submitting counter-proofs, thereby obviating the twin evils of idleness on the part of employees and attrition and undue delay on the part of employers. In line with this policy and in the interest of justice and equity, the Court fixed the deduction for earnings elsewhere at one-third of the total award, resulting in a net amount of P4,012,090.42 for backwages, overtime pay, and night differential pay.
Main Doctrine
The National Labor Relations Commission (NLRC) acted without jurisdiction when it set aside or further modified a final and executory resolution of the Court of Industrial Relations (CIR) that was previously upheld by the Supreme Court, by ordering a total reopening of an approved computation of award instead of a limited reopening as previously directed. Such an act renders the NLRC's subsequent decision null and void. The Court also reiterated the policy of fixing backwages at a reasonable level without qualification or deduction to avoid protracted delays.