Aris (Phil.) Inc. vs. National Labor Relations Commission et al.

Posted Aug 5, 1991

By Anonymous

6 min read

Case Title and Citation

ARIS (PHIL.) INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER FELIPE GARDUQUE III, LEODEGARIO DE GUZMAN, LILIA PEREZ, ROBERTO BESTAMONTE, AIDA OPENA, REYNALDO TORIADO, APOLINARIO GAGAHINA, RUFINO DE CASTRO, FLORDELIZA RAYOS DEL SOL, STEVE SANCHO, ESTER CAIRO, MARIETA MAGALAD, and MARY B. NADALA, respondents.
G.R. No. 90501, August 5, 1991
Supreme Court - En Banc
Ponente: DAVIDE, JR., J.

Facts

Section 12 of Republic Act No. 6715 (effective March 21, 1989) amended Article 223 of the Labor Code to provide that a labor arbiter’s decision reinstating a dismissed or separated employee “in so far as the reinstatement aspect is concerned, shall immediately be executory, even pending appeal,” and that posting of a bond by the employer shall not stay such execution.
The NLRC promulgated “NLRC Interim Rules On Appeals Under R.A. No. 6715” on August 8, 1989; Section 2 mirrored Section 12 on immediate execution of reinstatement and Section 17 provided a transitory provision for appeals filed on or after March 21, 1989 but prior to the interim rules’ effectivity.
On April 11, 1988, private respondents (employees of petitioner) requested a grievance conference over hazardous working conditions; they later marched to management’s office after no conference was arranged.
On April 12, 1988, petitioner issued memoranda requiring explanations and thereafter dismissed the identified employees for alleged violations, including inciting or participating in illegal strikes.
Private respondents filed complaints for illegal dismissal docketed NLRC-NCR-00-0401630-88.
Labor Arbiter Felipe Garduque III rendered a decision on June 22, 1989 ordering reinstatement of the named complainants within ten days, with limited backwages of six months (except for one complainant); other claims were denied.
Complainants filed a Motion for Issuance of a Writ of Execution on July 19, 1989 relying on Section 12 of R.A. No. 6715.
Petitioner filed an appeal on July 21, 1989; complainants filed partial appeals on July 26 and August 10, 1989.
Petitioner opposed the motion for execution on August 29, 1989, arguing Section 12 could not be applied retroactively to pending cases and that retroactive reinstatement would burden its right to appeal.
Labor Arbiter issued an Order on October 5, 1989 granting execution as to reinstatement and issuing partial writs of execution; the Order referenced Section 17 of the NLRC Interim Rules.
Petitioner filed the present petition for certiorari on October 26, 1989 challenging the constitutionality of Section 12 of R.A. No. 6715, Section 2 of the NLRC Interim Rules, and the validity of Section 17 (transitory provision), and alleging excess of jurisdiction and due process violations.

Issues

Does Section 12 of R.A. No. 6715 and Section 2 of the NLRC Interim Rules, insofar as they provide for immediate execution of the reinstatement aspect of a labor arbiter’s decision even pending appeal, violate the constitutional guarantee of due process as oppressive or unreasonable?
Can Section 12 of R.A. No. 6715 and the NLRC interim procedural rules be applied retroactively to cases and decisions pending at the time of the statutes’ or rules’ effectivity?
Is Section 17 (the Transitory Provision) of the NLRC Interim Rules invalid or inapplicable as applied in this case?

Ruling

No - The Court held that Section 12 of R.A. No. 6715 and Section 2 of the NLRC Interim Rules are constitutional; the immediate executory nature of reinstatement orders pending appeal is a valid exercise of the State’s police power and a permissible limitation on the statutory privilege of appeal.
No - The Court held that the amendment and the NLRC interim procedural rules are procedural/remedial in character and therefore may be applied to pending cases; there is no vested right in procedural rules.
No - The Court found the reference to Section 17 in the Labor Arbiter’s Order unnecessary for the present case but held that the interim rules, including transitory provisions, may validly be given retroactive effect as procedural rules.

Reasoning / Ratio Decidendi

Statutory Nature of Appeal and Execution:
- The Court emphasized that the right to appeal is a statutory privilege, not a constitutional right, and the legislature may condition, limit, or provide relief to prevailing parties during appeals. The law may provide execution pending appeal as such relief; the Revised Rules of Court already permit execution pending appeal at the discretion of the court (Section 2, Rule 39).
Protection of Labor and Police Power:
- The Court grounded the contested provision in the State’s duty to afford full protection to labor under the Constitution (Article XIII, Section 3 and Article II, Section 18), deeming the provision a valid exercise of police power intended to protect employees deprived of livelihood by unjust dismissal.
- The immediate execution of reinstatement pending appeal was seen as a compassionate and constitutionally consistent policy to prevent continued deprivation of the employee’s means of support.
Presumption of Constitutionality:
- Laws are presumed constitutional; to invalidate a statute there must be a clear and unequivocal breach of the Constitution. The Court applied the saving construction principle and cited precedents requiring clear proof to nullify statutes (e.g., Parades v. Executive Secretary; La Union Electric Cooperative v. Yaranon; Peralta v. Commission on Elections).
Retroactivity of Procedural Rules:
- The Court treated the NLRC interim rules and the amendment as procedural/remedial. Procedural statutes and rules may be given retroactive effect; there are no vested rights in rules of procedure. The Court cited authorities recognizing retroactive application of remedial or procedural laws (e.g., People v. Sumilang; Enrile v. Court of First Instance).
Section 17:
- The Court observed that invoking Section 17 in the Labor Arbiter’s Order was unnecessary because the appeal procedure itself was not at issue; nonetheless, the transitory provision could validly apply to appeals filed on or after March 21, 1989 and before the interim rules’ effectivity.

Doctrine / Legal Principle

Execution pending appeal is a permissible legislative remedy and can be mandated for specific categories of judgments (here, reinstatement orders).
The right to appeal is a statutory privilege subject to reasonable legislative regulation.
Laws are presumed constitutional; courts should avoid declaring statutes unconstitutional unless clearly beyond doubt.
Procedural and remedial statutes and rules may be applied retroactively to pending cases; there are no vested rights in rules of procedure.
The State may exercise its police power to enact measures that protect labor, including immediate enforcement of reinstatement orders to safeguard employees’ livelihood.

Disposition

The petition is DISMISSED for lack of merit. Costs are assessed against petitioner.
The Labor Arbiter’s Order granting execution of the reinstatement aspect of the June 22, 1989 decision was sustained insofar as it conformed with Section 12 of R.A. No. 6715 and Section 2 of the NLRC Interim Rules.

Concurring / Dissenting Opinions

The decision was delivered by Justice Davide, Jr., with concurrence by Chief Justice Fernan and Justices Narvasa, Melencio-Herrera, Gutierrez, Jr., Cruz, Paras, Feliciano, Gancayco, Padilla, Bidin, Sarmiento, Griño-Aquino, Medialdea and Regalado.
No dissenting opinions are indicated in the decision.

Significance / Notes

Confirms that reinstatement orders by labor arbiters are immediately executory even during appeal; employers cannot stay reinstatement by posting bond.
Clarifies that the legislature may prioritize protection of labor by limiting the practical effect of appeals in specific contexts.
Affirms the principle that procedural or remedial rules promulgated by tribunals (here, NLRC interim rules under Article 218(a) of the Labor Code) may be applied retroactively to pending cases.
Emphasizes the heavy presumption of constitutionality and the high threshold for invalidating statutes on due process grounds.
Practical impact: employers facing reinstatement orders must comply pending appeal unless a final court determination overturns the decision; litigation strategy must account for compulsory interim compliance in reinstatement cases.

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