G.R. No. 113827 July 5, 1996
PHILIPPINE AIRLINES, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, ARBITER RAMON VALENTIN C. REYES, AND STELLAR EMPLOYEES ASSOCIATION, respondents.

FACTS

Philippine Airlines (PAL) is the petitioner in this case involving numerous complaints for regularization and illegal dismissal filed by approximately 150 individuals recruited by Stellar Industrial Services, Inc. (SISI) to work for PAL. The cases were consolidated into two groups: one for regularization before Labor Arbiter Jose de Vera, and another for illegal dismissal before Labor Arbiter Ramon Valentin C. Reyes. Labor Arbiter de Vera had already rendered a decision declaring the complainants as regular employees of PAL, which was pending appeal before the NLRC. Separately, Labor Arbiter Reyes, in a decision dated December 10, 1992, also declared the complainants’ dismissal illegal, ordering their reinstatement and payment of back wages and benefits. PAL appealed this decision as well.
Pending the resolution of these appeals, Labor Arbiter Reyes, upon the complainants’ motion, issued a writ of execution on April 2, 1993, directing the reinstatement of 152 complainants. To halt this execution, PAL filed a petition for injunction with the NLRC. The NLRC dismissed PAL’s petition in a Resolution dated September 30, 1993, citing Article 223 of the Labor Code, which mandates the immediate executory nature of a reinstatement order even pending appeal. PAL’s motion for reconsideration was subsequently denied.

ISSUE

Did the National Labor Relations Commission commit grave abuse of discretion in dismissing PAL’s petition for injunction and denying its motion for reconsideration, thereby allowing the immediate execution of the reinstatement order?

RULING

No, the NLRC did not commit grave abuse of discretion. The Supreme Court upheld the NLRC’s application of Article 223 of the Labor Code, as amended. The legal provision explicitly states that a Labor Arbiter’s decision ordering reinstatement shall be immediately executory, even pending appeal. The employer is given the option to either physically readmit the employee or reinstate them in the payroll. The posting of a bond does not stay this execution.
The Court rejected PAL’s argument that Article 223 is inapplicable because it contests the existence of an employer-employee relationship. The law’s intent is to restore the status quo in the workplace while the merits of the case are on appeal, functioning similarly to a return-to-work order. The factual findings of the Labor Arbiters, which declared the complainants as regular employees of PAL, are accorded respect and finality when supported by substantial evidence. At this procedural juncture, the Court’s review is limited to the propriety of the NLRC’s dismissal of the injunction petition, not the underlying merits of the employment case. The NLRC was merely enforcing the clear mandate of the law, and its action was devoid of any grave abuse of discretion warranting correction by certiorari. The petition was therefore dismissed.