G.R. No. 251518 , November 27, 2024
DEL MONTE LAND TRANSPORT BUS COMPANY, DON L. MORALES, AND EILEEN FLORES, PETITIONERS, VS. ROMEO M. JARANILLA, MARLON H. GUANTERO, AND JESUS B. DOMANAIS, RESPONDENTS.

FACTS

This case originated from consolidated complaints for illegal dismissal filed by respondents against petitioners. On November 25, 2013, the Labor Arbiter (LA) ruled that respondents were illegally dismissed. The NLRC initially reversed this decision on April 23, 2014, but upon respondents’ motion for reconsideration, reinstated the LA’s decision on October 31, 2014. Pending a petition for certiorari filed by petitioners with the Court of Appeals (CA), respondents secured a writ of execution and received partial payment of the judgment award. On June 30, 2015, the CA granted petitioners’ petition, annulled the NLRC’s October 31, 2014 Resolution, and declared respondents legally dismissed. This CA Decision became final on November 24, 2015. Subsequently, respondents filed a Motion for Issuance of Alias Writ of Execution, claiming entitlement to reinstatement wages from December 2014 until the finality of the CA Decision reversing the LA’s ruling. The LA granted the motion, ordering payment of reinstatement wages from November 25, 2013 to April 23, 2014, and from October 31, 2014 to June 30, 2015. The NLRC and the CA affirmed this ruling. Petitioners now argue before the Supreme Court that respondents are no longer entitled to such wages due to the final CA ruling on legal dismissal and that petitioners are entitled to restitution of amounts already paid.

ISSUE

1. Whether the CA gravely erred in affirming that respondents are entitled to reinstatement wages for the period from October 31, 2014 to June 30, 2015.
2. Whether the CA gravely erred in disregarding petitioners’ right to restitution of the amounts paid under the executed LA decision.

RULING

The Supreme Court denied the petition, ruling that it was bereft of merit.
1. On entitlement to reinstatement wages: The Court held that respondents were entitled to reinstatement wages from November 25, 2013 (the date of the LA’s reinstatement order) until June 30, 2015 (the date of the CA’s final reversal). Citing Article 229 (formerly Article 223) of the Labor Code and jurisprudence (Roquero v. Philippine Airlines, Genuino v. National Labor Relations Commission, Bergonio v. South East Asian Airlines), the Court reiterated that an order of reinstatement is immediately executory, even pending appeal. The employer must either actually reinstate the employee or reinstate them in the payroll. The accrual of reinstatement wages ceases only when the reinstatement order is finally reversed. In this case, the LA’s November 25, 2013 order was immediately executory. Although the NLRC reversed it on April 23, 2014, the NLRC’s subsequent October 31, 2014 Resolution reinstating the LA’s decision revived the immediately executory reinstatement order. Therefore, respondents were entitled to wages from the original LA order date until the CA’s final reversal on June 30, 2015.
2. On the right to restitution: The Court ruled that petitioners are not entitled to restitution of the amounts already paid to respondents. The payment was made pursuant to the immediately executory reinstatement order. Jurisprudence establishes that benefits received by an employee under an immediately executory reinstatement order, pending appeal, need not be reimbursed even if the decision is later reversed, as the order was lawful and enforceable at the time it was implemented. The Court cited Garcia v. Philippine Airlines and Wenphil Corporation v. Abing to emphasize that the law intends the employee to immediately enjoy the reinstatement order’s benefits, and requiring restitution would negate the provision’s immediate executory nature.