G.R. No. L-71413 March 21, 1988
D. M. CONSUNJI, INC., petitioner, vs. HON. SEVERO M. PUCAN, ACTING DEPUTY SHERIFF ALFREDO ANTONIO, JR., and PONCIANO FELICIA, respondents.

FACTS

Private respondent Ponciano Felicia, a regular employee of D. M. Consunji, Inc. since 1959, was a finishing carpenter at the company’s main office. After a period of hospitalization in 1978, he was given a memorandum transferring him to a workshop in Cainta, described as temporary. Felicia refused the transfer, believing it was a scheme for his eventual dismissal. The company treated his refusal as insubordination. Felicia subsequently filed a complaint for illegal dismissal.
The Ministry of Labor and Employment found the dismissal illegal, ordering Felicia’s reinstatement with full backwages from May 11, 1978. This order was affirmed on appeal in 1981. In 1984, a writ of execution was issued for backwages covering over five years. The company complied with the monetary aspect via garnishment but refused reinstatement. Consequently, in 1985, an alias writ of execution was issued for additional backwages from 1984 onward, prompting the company’s petition to annul it.

ISSUE

Whether the alias writ of execution, awarding backwages beyond the three-year maximum period established by jurisprudence, is valid.

RULING

The Supreme Court granted the petition, setting aside the alias writ. The legal logic is anchored on the consistent application of the jurisprudential rule limiting backwages for illegally dismissed employees to three years. This rule, a policy determination by the Court, aims to expedite labor case disposition and avoid the twin evils of employee idleness and employer delay in satisfying awards.
The Court clarified that this three-year limit applies strictly to the computation of the monetary award, not to the execution process itself. While the delay in Felicia’s reinstatement was attributable to the company’s obstinate refusal to comply with final orders, this did not justify an award exceeding the three-year cap. The policy seeks to prevent employees from unduly delaying their own reinstatement to accumulate backwages. The Court noted Felicia had already received a considerable sum covering more than three years via the first writ. Therefore, while the company was ordered to immediately reinstate Felicia, any further monetary execution beyond the three-year backwages was invalid. The ruling reinforces the finality of the three-year rule as a substantive limitation on backpay, irrespective of delays in enforcement caused by a recalcitrant employer.