G.R. No. 104860 . July 11, 1996. CITYTRUST BANKING CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and MARIA ANITA RUIZ, respondents.
FACTS:

Private respondent Maria Anita Ruiz, the internal auditor of petitioner Citytrust Banking Corporation, was illegally dismissed in 1974 after refusing a managerial appointment she deemed a demotion. The Office of the President ultimately ordered her reinstatement to a substantially equivalent position with full backwages. Petitioner reinstated her as Manager of the Auditing Department in 1978, but this was contested as not substantially equivalent to the position of Resident Inspector, which had replaced her former role. Labor Arbiter Apolinario Lumabao, in an order affirmed by the NLRC, ruled the reinstatement was improper and directed her reinstatement to the position of Resident Inspector or a substantially equivalent one, with payment of salary differentials and other benefits.
Subsequent proceedings involved protracted disputes over the computation of monetary awards. A key development was this Court’s resolution in G.R. No. 72589 (July 21, 1986), which limited the award of backwages for the period of illegal dismissal to three years, in accordance with prevailing jurisprudence. However, a separate component for salary differentials—covering the period from her reinstatement to the inferior managerial position in 1978 until her retirement in 1991—remained for computation. Petitioner’s present certiorari petition seeks to annul NLRC resolutions denying its plea to stop the execution of this differential award.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in issuing the alias writ of execution for the payment of salary differentials to private respondent.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The legal logic is clear and twofold. First, the Court affirmed the finality of the Labor Arbiter’s 1979 order, as sustained by the NLRC and this Court in prior resolutions, which established that Ruiz’s reinstatement as Manager of the Auditing Department was not substantially equivalent to the position of Resident Inspector. This final determination created a continuing entitlement to salary differentials for the period she occupied the lesser position until her retirement. Second, the Court distinguished this award from the separate award of backwages for the period of illegal dismissal. The backwages were correctly limited to three years by the Court’s 1986 resolution. The salary differentials, however, constitute a distinct and compensatory award for the employer’s failure to reinstate the employee to a substantially equivalent position as finally adjudged. This differential ensures the employee is made whole for the employer’s ongoing non-compliance with the reinstatement order, a principle fundamental to labor justice. The Court emphasized that this fourth petition unduly prolonged litigation and remanded the case solely for the ministerial computation of the differentials from August 14, 1978, to March 1, 1991.