GR L 23015; (May, 1972) (Digest)
G.R. No. L-23015, May 30, 1972.
COLGATE-PALMOLIVE PHILIPPINES, INC., petitioner, vs. DOMINADOR DE LA CRUZ, et al., and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
Petitioner Colgate-Palmolive dismissed several employees who subsequently charged the company with unfair labor practice before the Court of Industrial Relations (CIR). After hearing, the CIR absolved the company of the unfair labor practice charge and dismissed the complaint for lack of merit. However, in the same decision, the CIR, citing justice and equity, directed its Chief Examiner to compute and determine the money value of other rights and privileges due to the dismissed employees, such as accrued vacation and sick leave and bonuses. This decision became final and executory as the petitioner did not appeal.
Pursuant to the directive, the CIR Chief Examiner submitted a report finding that the employees had not been paid the cash equivalent of their unused sick leave. The petitioner objected, arguing that the CIR, having absolved it of the unfair labor practice charge, lost jurisdiction to award monetary claims, which should be filed in a regular court. The CIR, through an order, directed the petitioner to deposit the amount for the unused sick leave, which order was affirmed by the CIR en banc.
ISSUE
Whether the CIR retained jurisdiction to order the payment of the cash equivalent of unused sick leave after it had absolved the employer of the unfair labor practice charge and the decision had become final.
RULING
Yes. The Supreme Court affirmed the CIR’s orders. The legal logic rests on the principle of finality of judgments and the CIR’s ancillary jurisdiction. The CIR’s original decision, which became final, contained a definitive directive for the Chief Examiner to compute the monetary value of certain benefits. This directive was an integral part of the final judgment. By not appealing this specific portion of the decision, the petitioner acquiesced to it.
The Court ruled that the CIR retained jurisdiction to execute and implement its final decision. The order for payment was not a new adjudication of a separate money claim but a mere implementation or ministerial enforcement of a final judgment that had already determined the employees’ entitlement to these benefits based on equity. The objection to the payment of sick leave was a substantive defense that should have been raised on appeal; it could not be raised to collaterally attack the final judgment during its execution. Consequently, the CIR acted within its authority in issuing the orders to effectuate the terms of its final decision.