G.R. No. 221967 February 6, 2019
Ramiro Lim & Sons Agricultural Co., Inc., Sima Real Estate Development, Inc., and Ramiro Lim, Petitioners vs. Armando Guilaran, et al., Respondents

FACTS

Respondents, agricultural workers on petitioners’ hacienda, filed complaints for illegal dismissal and monetary claims. The Labor Arbiter initially dismissed the complaints, finding abandonment, but the Court of Appeals (CA) reversed, declaring the dismissal illegal and ordering reinstatement with backwages. The Supreme Court denied petitioners’ subsequent appeal, and this denial became final on November 17, 2009. For execution, the Labor Arbiter, adopting a Fiscal Examiner’s computation, awarded uniform backwages to each respondent based on six months of work per year from 2000 to 2009, totaling over Five Million Pesos.
Petitioners appealed this computation to the National Labor Relations Commission (NLRC). The NLRC annulled the Labor Arbiter’s Order, finding the uniform six-month-per-year formula erroneous. It instead computed backwages based on petitioners’ submitted payrolls, determining each respondent’s average monthly income for the twelve months preceding dismissal and applying prevailing Wage Orders. Respondents then filed a certiorari petition with the CA, challenging the NLRC’s computation.

ISSUE

Whether the Court of Appeals erred in setting aside the NLRC’s computation of backwages and reinstating the Labor Arbiter’s computation.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The CA correctly found that the NLRC committed grave abuse of discretion in relying on the payrolls submitted by petitioners for its computation. The CA conducted a meticulous examination and found the signatures on the payrolls inconsistent and questionable, rendering the documents unreliable and self-serving. The presumption of regularity accorded to entries in the course of business was sufficiently overcome by these patent irregularities.
Consequently, the NLRC’s factual findings, being based on extremely doubtful evidence, were not binding. The CA was justified in reinstating the Labor Arbiter’s computation, which was based on the mandated wage rates. The Court further modified the award by imposing legal interest on the total monetary awards: twelve percent (12%) per annum from November 17, 2009 (the date of finality of the illegal dismissal ruling) until June 30, 2013, and six percent (6%) per annum from July 1, 2013, until full satisfaction. The petition was denied for lack of merit.