G.R. No. L-39174 and G.R. No. L-39186. May 7, 1976.
JACKBILT CONCRETE BLOCK CO., INC. and ALBERT GOLDEN, petitioners, vs. NORTON & HARRISON CO. and JACKBILT CONCRETE BLOCK CO. LABOR UNION-NLU and COURT OF INDUSTRIAL RELATIONS, respondents. NORTON & HARRISON CO., INC., petitioner, vs. NORTON & HARRISON CO. and JACKBILT CONCRETE BLOCK CO. LABOR UNION-NLU and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

In a prior case (G.R. No. L-18461), the Supreme Court ordered the petitioners (the companies and manager) to reinstate, without back wages, the union strikers who offered to return to work on October 23, 1958. The reinstatement order was based on the finding that the strike was undertaken in good faith, believing the company committed unfair labor practice, though the company was ultimately absolved of that charge. The Court directed reinstatement to occur sixty days after the decision’s finality. After the decision became final, the strikers presented themselves for work on September 7, 1967, but were not accepted. The companies had earlier filed a motion for clarification with the Supreme Court, citing plant automation and modernization that reduced the workforce, making full reinstatement impossible. The Supreme Court denied that motion, stating such execution issues should be addressed by the Court of Industrial Relations (CIR).
The union then filed motions with the CIR to compel reinstatement and to award back wages from September 7, 1967. The CIR, in its contested orders, granted the motions. It ordered the companies to reinstate the strikers, awarded them back wages from September 7, 1967, and granted separation pay to those found medically unfit. The companies challenged these orders, arguing the CIR exceeded its authority by modifying the final Supreme Court decision which had denied back wages and by awarding separation pay.

ISSUE

Did the Court of Industrial Relations commit grave abuse of discretion in awarding back wages and separation pay to the strikers, thereby altering the final and executory judgment of the Supreme Court?

RULING

Yes. The Supreme Court ruled that the CIR committed grave abuse of discretion. The legal logic is anchored on the doctrine of finality of judgment and the limited scope of execution. The Supreme Court’s decision in G.R. No. L-18461 was final and executory. It specifically ordered reinstatement “without back wages.” The CIR, in the execution phase, cannot amend, modify, or alter this substantive ruling. By awarding back wages from September 1967, the CIR effectively granted a monetary benefit the Supreme Court had expressly withheld, which constitutes a usurpation of judicial power and a violation of the principle of immutability of final judgments.
Furthermore, the award of separation pay was also erroneous. The Termination Pay Law (R.A. 1052) requires such payment only when an employer dismisses an employee without just cause. Here, the strikers were not dismissed; they struck and were ordered reinstated. Their employment status was merely suspended, not terminated. Therefore, no legal basis existed for separation pay. For strikers found medically unfit, the proper remedy was not separation pay but a directive for them to secure a certification of fitness from a government physician as a precondition for reinstatement, as established in precedent. The CIR’s orders were set aside insofar as they awarded back wages, granted another period to report for work, and granted separation pay. The companies were directed to reinstate medically unfit strikers only upon presentation of the required government physician’s certification.