G.R. Nos. L-61719-20 February 28, 1985
Government Service Insurance System, petitioner, vs. National Labor Relations Commission, GSIS Supervisors’ Union (GSISSU), and GSIS Employees Association-PAGE, respondents.

FACTS

The controversy originated from two cases before the defunct Court of Industrial Relations (CIR). In 1968, petitioner GSIS implemented a new pay scale. However, a select group of employees, including those under Manuel Perlada and members of the GSISEA-CUGCO union, received a higher, one-rate salary adjustment. Respondents GSISSU and GSISEA-PAGE, whose members did not receive this benefit, filed petitions demanding the same one-rate increase effective January 1, 1968. The CIR ruled in favor of the unions, ordering GSIS to grant their members the same salary readjustment as the Perlada group, provided they had not reached the maximum step of their pay class. This Court affirmed the CIR orders in a joint Decision dated April 30, 1979.
Subsequently, GSIS made partial payments covering salary differentials for the period January 1, 1968 to June 30, 1969. In 1980, GSIS filed an Omnibus Motion with the NLRC for entry of satisfaction of judgment, claiming full payment. The unions opposed, arguing entitlement to differentials from January 1, 1968 until their salaries were superseded by higher rates, which for many extended to 1975. The NLRC denied GSIS’s motion and ordered further computation and payment. GSIS filed this certiorari petition, arguing the NLRC committed grave abuse of discretion by extending the payment period beyond June 30, 1969.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in ruling that the implementation of the Supreme Court’s affirmed judgment required payment of salary differentials beyond June 30, 1969.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the NLRC. The legal logic centered on the precise nature of the relief granted and affirmed. The core mandate of the CIR orders, as affirmed by this Court, was to correct GSIS’s discriminatory act by granting the complaining union members the same one-rate increase already given to the Perlada group. The Court clarified that the obligation to grant this equalizing adjustment persisted for as long as the Perlada group continued to receive the benefit. The NLRC’s factual finding was that the Perlada group received the increases until they were extended a different rate, or up to October 1975. Since the affirmed judgment required identical treatment, the payment period for the union members logically extended for the same duration. The Court emphasized that the question of the exact period was one of fact, and the NLRC’s determination, being supported, would not be disturbed. The judgment could not be deemed satisfied until the discriminatory practice was fully rectified by equalizing the benefits for the entire period the favored group enjoyed them. Thus, the NLRC correctly denied GSIS’s motion for entry of satisfaction.