G.R. No. L-26124 and G.R. No. L-32725. May 29, 1971.
CONRADO CASTILLO, SILVESTRE ASTORGA, VALENTIN OFILADA, and SIMPLICIO DAMULO, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, MAYFAIR THEATRE, INC., and/or HENRY YANG, respondents. (and the consolidated case of MAYFAIR THEATRE, INC., and/or HENRY YANG, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, SILVESTRE ASTORGA and CONRADO CASTILLO, respondents.)

FACTS

The case originated from an unfair labor practice complaint filed by four employees against Mayfair Theatre, Inc. for alleged arbitrary dismissal due to union activities. The Court of Industrial Relations (CIR) found the dismissals of Valentin Ofilada and Simplicio Damulo justified, but ruled that Silvestre Astorga and Conrado Castillo were illegally dismissed for union activities. It ordered their reinstatement, granting back wages to Castillo but denying them to Astorga. Both parties moved for reconsideration. Subsequently, the CIR, noting that Astorga and Castillo had been convicted in criminal cases (for threats and slight physical injuries) which were on appeal, ordered that their reinstatement be held in abeyance pending final resolution of those criminal cases. This 1964 resolution is challenged in G.R. No. L-26124 by the employees.
In 1969, after the criminal case for threats was dismissed and Astorga’s conviction for slight physical injuries (from a 1962 incident unrelated to the dismissal) became final, Astorga and Castillo moved for immediate reinstatement. The CIR granted the motion, ordering their reinstatement and directing the computation of Castillo’s back wages. Mayfair Theatre challenged this 1969 order via certiorari in G.R. No. L-32725, arguing the CIR interfered with the Supreme Court’s pending review in L-26124 and that Astorga’s criminal conviction barred reinstatement.

ISSUE

The primary issues are: (1) Whether the CIR correctly held the reinstatement of Astorga and Castillo in abeyance pending their criminal appeals; (2) Whether the CIR’s subsequent 1969 order for their reinstatement, despite Astorga’s final conviction, was valid; and (3) Whether the 1969 order constituted an improper interference with the Supreme Court’s jurisdiction in the then-pending G.R. No. L-26124.

RULING

The Supreme Court dismissed both petitions and affirmed the CIR’s orders, with modifications on back wages. On the first issue, the Court found the initial deferment of reinstatement pending criminal appeals was a prudent exercise of the CIR’s discretion, as the outcomes could potentially affect the employees’ rights. On the second issue, the Court upheld the 1969 reinstatement order. Astorga’s conviction for slight physical injuries, which occurred years after his illegal dismissal and was unrelated to it, did not automatically disqualify him from reinstatement. The CIR, in its discretion, correctly did not treat this unrelated conviction as a sufficient ground to deny reinstatement altogether, especially since Astorga was denied back wages for the period of his illegal dismissal. Regarding Castillo, the criminal case against him had been dismissed. On the third issue, the Court found no interference with its jurisdiction. The 1969 order implemented the CIR’s final judgment on the merits of the illegal dismissal, which was distinct from the issue of the propriety of the deferment under review in L-26124. The Court modified the back wage awards: Castillo is entitled to back wages from his 1959 dismissal until