G.R. No. L-39889. March 29, 1984.
UNION OF SUPERVISORS (RB) NATU, Petitioner, vs. THE SECRETARY OF LABOR AND REPUBLIC BANK, Respondents.

FACTS

The Supreme Court, in a November 12, 1981 decision, found Norberto Luna’s discharge by Republic Bank (now Republic Planters Bank) to be discriminatory and an unfair labor practice. The Court ordered his immediate reinstatement to his former position as San Juan Branch Manager without loss of seniority rights and benefits, with full back wages equivalent to three years without qualification, and declared the decision immediately executory. Upon receiving the decision, Luna presented himself for work, but the bank refused reinstatement, stating the decision was under study.
Subsequently, Republic Planters Bank filed a manifestation, arguing it should not be liable for the unfair labor practice committed by the old management of the defunct Republic Bank. It detailed a corporate restructuring in 1978, involving a takeover by the Philippine Sugar Commission and other government entities, which saved the bank from collapse. The new management claimed it was unaware of the pending case and argued that reinstating Luna as Branch Manager would disrupt its reorganized operations and violate the security of tenure of the current incumbent. It sought to qualify the reinstatement order by allowing it to place Luna in an equivalent position instead.

ISSUE

Whether Republic Planters Bank, as the corporate successor, can avoid the reinstatement order and the unqualified three-year back wage award based on its change in management and corporate structure.

RULING

The Court denied the bank’s plea. The legal logic is anchored on the doctrine of corporate continuity and the imperative nature of labor decree execution. A change in corporate ownership, management, or name does not extinguish the corporation’s liabilities or alter its juridical personality. Republic Planters Bank remained the same corporate entity liable for the unfair labor practice judgment. The defense of being a new management, unaware of the case, is immaterial; the corporation itself was the party to the proceedings and is bound by the judgment.
Regarding reinstatement, while the bank cannot be compelled to displace a current innocent employee, it must reinstate Luna to a substantially equivalent position without loss of seniority rights. On the matter of back wages, the Court affirmed its policy of awarding three years’ back pay without qualification or deduction. This policy is designed to prevent delay in execution and protect employees from the economic hardship of protracted litigation. It obviates the need for proof of interim earnings, ensuring swift justice. Since the bank had already paid the three-year back wages, no deductions were permitted. The resolution was made immediately executory to enforce the worker’s rights without further delay.