GR 146408; (April, 2009) (Digest)
G.R. No. 146408 ; April 30, 2009
PHILIPPINE AIRLINES, INC., Petitioner, vs. ENRIQUE LIGAN, et al., Respondents.
FACTS
This is a Resolution on the Motions for Reconsideration filed by both parties following the Court’s February 29, 2008 Decision. The original Decision affirmed with modification the Court of Appeals’ ruling, declaring Synergy Services Corporation (Synergy) a labor-only contractor and, consequently, declaring the respondents as regular employees of petitioner Philippine Airlines, Inc. (PAL). The dispositive portion ordered PAL to accept the respondents as regular employees and pay corresponding wages, benefits, and salary differentials, while remanding the case to the Labor Arbiter for computation of monetary liabilities. In their motions, both parties revealed supervening events not previously brought to the Court’s attention: (1) except for those who died, accepted settlement, or were declared Synergy employees, the remaining respondents had been terminated under the guise of retrenchment; (2) thirteen respondents had a separate illegal dismissal case (CA-G.R. SP No. 00922) pending before the Cebu appellate court, which was held in abeyance pending this Court’s resolution; (3) respondent Roque Pilapil had been validly dismissed in a separate case for submitting falsified credentials, and PAL had already satisfied the judgment awarding him separation pay; and (4) respondent Benedicto Auxtero had already obtained a favorable judgment in another case (G.R. No. 158710), which PAL satisfied, and Auxtero had waived reinstatement.
ISSUE
Whether the February 29, 2008 Decision should be modified in light of the supervening events involving the termination of respondents and the separate final judgments regarding respondents Pilapil and Auxtero.
RULING
The Court MODIFIED its February 29, 2008 Decision. The claims regarding respondents Roque Pilapil and Benedicto Auxtero were deemed extinguished, as supervening final judgments had already resolved their status and claims. Pilapil’s regular employee status yielded to the final finding of valid dismissal for misconduct, while Auxtero’s case was barred by forum-shopping and satisfaction of judgment. The Court clarified that its original Decision, which ruled on the regular status of respondents, was without prejudice to the resolution of the illegal dismissal issue in the proper forum (CA-G.R. SP No. 00922). The Court emphasized that the original complaint was for regularization and underpayment of benefits, not illegal dismissal; thus, it did not and could not rule on the validity of the subsequent termination. The issue of whether retrenchment due to alleged financial losses was a valid authorized cause for dismissal remained a factual matter to be resolved in the pending illegal dismissal case. The Court also denied respondents’ belated plea for attorney’s fees, as they did not appeal from the appellate court’s decision and could not seek affirmative relief not previously granted. The modified dispositive portion orders PAL to recognize the listed respondents (excluding Pilapil and Auxtero) as regular employees and pay the corresponding wages, benefits, and salary differentials up to June 30, 1998 (the date of their lay-off), without prejudice to the resolution of the illegal dismissal case. The remand to the Labor Arbiter for computation of monetary liabilities was maintained.
