G.R. No. 88725 November 22, 1989
ASIAN TRANSMISSION CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION; COMMISSIONERS Ceferino Dulay, Mirasol Corleto and Roberto Tolentino; JOSE C. ESPINAS; and BISIG NG ASIAN TRANSMISSION LABOR UNION (BATLU), respondents.

FACTS

This case stems from a prior labor dispute where the Supreme Court, in its June 27, 1988 Decision, resolved the validity of a return-to-work order issued by the NLRC. The Court affirmed the NLRC’s authority to issue such an order pending the determination of a strike’s legality. Crucially, the Court ruled that the order imposes a mandatory duty on workers to return, not merely a waivable right. It found that forty-four (44) employees defied the order by staging a strike and picketing. Consequently, the Court held these defiant workers forfeited their employment and were not entitled to reinstatement or back wages, as they had abandoned their positions by refusing to comply.
After the case was remanded, the union (BATLU) filed a motion for execution, seeking the reinstatement of the remaining thirty-four workers. The NLRC granted the motion in a June 13, 1989 Resolution. It reasoned that the Supreme Court had affirmed its earlier resolution ordering reinstatement and that the return-to-work order inured to the benefit of all workers. Asian Transmission Corporation assailed this NLRC resolution via certiorari, arguing it constituted grave abuse of discretion by misinterpreting the Supreme Court’s final ruling.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in issuing its June 13, 1989 Resolution ordering the reinstatement of workers who had defied the return-to-work order.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court annulled and set aside the assailed NLRC Resolution. The Court clarified that its June 27, 1988 Decision explicitly distinguished between compliant and non-compliant workers. It affirmed the NLRC’s January 13, 1987 Resolution only “as above interpreted,” with the interpretation clearly delineated in the body of the decision. The ruling expressly stated that the return-to-work order benefits only those who obeyed it, entitling them to pay for work actually performed. Conversely, workers who refused to obey the order and instead waged a strike were not entitled to reinstatement or payment, having abandoned their jobs. The NLRC’s resolution, by ordering the reinstatement of the defiant workers, directly contravened this explicit holding. Its action was based on a fundamental misreading of the final and executory Supreme Court decision, rendering it a whimsical and capricious exercise of power amounting to grave abuse of discretion. Execution of the prior decision to compel reinstatement of these forty-four workers was perpetually restrained.