GR 90501; (August, 1991) (Digest)

G.R. No. 90501; August 5, 1991
ARIS (PHIL.) INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER FELIPE GARDUQUE III, LEODEGARIO DE GUZMAN, et al., respondents.

FACTS

Private respondents, employees of petitioner Aris (Phil.) Inc., were dismissed after participating in a protest rally concerning workplace conditions. They filed a complaint for illegal dismissal. On June 22, 1989, Labor Arbiter Felipe Garduque III rendered a decision ordering their reinstatement with limited backwages. The decision was rendered after the effectivity on March 21, 1989, of Republic Act No. 6715, which amended Article 223 of the Labor Code. Private respondents moved for the issuance of a writ of execution for reinstatement pending appeal, invoking the new law’s provision that a reinstatement order is immediately executory. Petitioner opposed, arguing the law could not be applied retroactively to its pending appeal and assailing its constitutionality for violating due process and equal protection.

ISSUE

The primary issue is whether Section 12 of R.A. No. 6715, allowing immediate execution of a reinstatement order pending appeal, is constitutional and applicable to a decision rendered after its effectivity but concerning a dismissal that occurred prior thereto.

RULING

The Supreme Court upheld the constitutionality of the provision and its application. The law is a valid exercise of the State’s police power to promote social justice and protect labor, as mandated by the Constitution. The immediate execution rule is a procedural mechanism designed to address the urgent need of a dismissed employee for reinstatement, preventing protracted litigation from depriving them of their livelihood. It does not violate due process as the employer retains the right to appeal the merits of the dismissal and seek reimbursement if the decision is reversed. The option for the employer to reinstate the employee “in the payroll” mitigates any operational disruption. The law applies to the case at bar as the Labor Arbiter’s decision was rendered after the law’s effectivity; thus, its application is prospective, not retroactive. Procedural rules, like this amendment, can be applied to pending proceedings. The NLRC Interim Rules implementing the provision are likewise valid as an exercise of quasi-legislative power. The petition was dismissed for lack of merit.