G.R. No. L-51077, December 27, 1979
CENTRAL TEXTILE MILLS, INC., petitioner, vs. UNITED (CMC) TEXTILE WORKERS UNION-TGWF, RUBEN ALMARIO, GABRIEL PUZON, NATIONAL LABOR RELATIONS COMMISSION and LABOR ARBITER FRANCISCO M. DE LOS REYES, respondents.

FACTS

The petitioner, Central Textile Mills, Inc., seeks to annul the execution of a final NLRC decision in Case No. LR-2658 ordering the reinstatement with backwages of employees Ruben Almario and Gabriel Puzon. In that unfair labor practice case, an arbitrator found Almario’s dismissal unjustified as his absence was due to tuberculosis, not abandonment, and held Puzon’s projected dismissal for a minor infraction as not constituting gross misconduct. This decision was affirmed up to the Presidential level.
However, a separate and final decision was rendered in another case, NLRC Case No. 9-4733-74, filed by Almario for separation pay. In that case, the NLRC found that Almario had in fact abandoned his job and was not entitled to separation pay. This created a direct inconsistency: one final decision ordered his reinstatement, while another found he had abandoned his employment. For Puzon, the record showed he had voluntarily resigned and executed a quitclaim, matters which were not squarely addressed in the reinstatement order.

ISSUE

Whether the execution of the final judgment in Case No. LR-2658 for the reinstatement with backwages of Almario and Puzon is just and proper, given the NLRC’s contradictory final ruling that Almario abandoned his job and considering Puzon’s resignation and quitclaim.

RULING

The Supreme Court ruled in the negative, setting aside the writ of execution and the conflicting decisions. The Court applied the principle that when, after a judgment becomes final, facts and circumstances arise which render its execution unjust or inequitable, a court may stay or prevent such execution. Here, the NLRC itself rendered two irreconcilable final decisions regarding Almario’s employment status. Enforcing the reinstatement order while another final ruling declares he abandoned his job would be a manifest injustice. For Puzon, his voluntary resignation and quitclaim, which constituted significant supervening facts, were not duly considered in the reinstatement order.
The Court held that simple justice and rudimentary fairness demand a rehearing. The NLRC was directed to consolidate the two cases for the purpose of reconciling the contradictory findings on Almario and to properly rule on the legal effect of Puzon’s resignation and quitclaim upon the union’s claim for his reinstatement. This procedural remedy is necessary to afford all parties a full opportunity to prove their contentions and to arrive at a just and coherent resolution, thereby preventing an inequitable enforcement of a judgment rendered dubious by the tribunal’s own inconsistent pronouncements.