G.R. No. 187713 , August 1, 2012. RADIO PHILIPPINES NETWORK, INC., et al., Petitioners, vs. RUTH F. YAP, et al., Respondents.
FACTS

Petitioner Radio Philippines Network, Inc. (RPN) terminated respondents, who were union members, based on a union security clause in their Collective Bargaining Agreement after the union expelled them. The Labor Arbiter (LA) found the dismissal illegal and ordered the respondents’ reinstatement with full backwages. RPN, through counsel, filed a Manifestation stating it had complied with the reinstatement order via “payroll reinstatement.” The respondents, however, alleged non-compliance. They presented themselves at RPN’s premises for work but were denied entry. On a subsequent payday, they were forcibly barred by guards from entering to collect their salaries, resulting in physical altercations and injuries. The respondents then filed a Motion to Cite for Contempt against RPN’s corporate officers.
The LA found the individual petitioners (corporate officers) guilty of indirect contempt for willfully disobeying the reinstatement order. The National Labor Relations Commission (NLRC) affirmed this. The petitioners filed a petition for certiorari with the Court of Appeals (CA), which was dismissed for procedural shortcomings, specifically their failure to attach certain required pleadings. The petitioners elevated the case to the Supreme Court via a petition for review.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari on procedural grounds, and whether the individual corporate officers were correctly held liable for indirect contempt for disobeying the Labor Arbiter’s reinstatement order.

RULING

The Supreme Court denied the petition and affirmed the contempt findings. On the procedural issue, the Court found the CA’s dismissal proper. The petitioners failed to attach the LA’s contempt order and other material portions of the record to their CA petition, a mandatory requirement under the Rules of Court. This failure prevented the CA from fully resolving the factual issues, warranting dismissal.
On the substantive issue, the Court upheld the contempt liability of the individual corporate officers. The law mandates that a reinstatement order is immediately executory. An employer must either actually reinstate the employee to their former position or, at its option, reinstate them in the payroll. Payroll reinstatement requires the employer to include the employee in its payroll and pay their salaries regularly as they become due, without requiring the employee to report for work. Here, RPN’s actions constituted a refusal to reinstate. Denying the respondents entry to receive their pay and subjecting them to forcible ejection violated the reinstatement order. The individual petitioners, as high-ranking officers with direct responsibility for company operations and compliance with the LA’s directive, were properly held liable for their willful disobedience. Their claim of merely following a policy to prevent intra-union conflict did not justify defying a judicial order. Contempt power is essential to uphold the authority of the court and its orders.