Frondozo vs. Manila Electric Company

The Supreme Court held that the NLRC did not commit grave abuse of discretion in granting MERALCO's prayer for a preliminary injunction to suspend execution proceedings due to conflicting final and executory decisions from different Court of Appeals divisions, one of which was affirmed by the Supreme Court on the merits upholding the employees' dismissal for participating in an illegal strike; the case was remanded to the NLRC for execution of the Supreme Court's prior resolutions affirming the dismissals.

The dispute arose from labor unrest at MERALCO involving unfair labor practices, union busting allegations, and strikes by rank-and-file employees under MEWA in 1991, certified to the NLRC for compulsory arbitration by the DOLE Secretary, resulting in terminations of union officers and members for alleged illegal acts during the strikes, and subsequent illegal dismissal complaints amid ongoing conciliation efforts and certifications that enjoined further strikes and ordered return-to-work.

MEWA filed a notice of strike on 16 May 1991 for unfair labor practice, leading to a strike on 6 June 1991; DOLE certified the dispute to NLRC, ordering return to work; MERALCO terminated seven petitioners (Frondozo, Perez, Zafra, Vito, Cruz, N. dela Cruz, Diloy) plus Dizon on 26 July 1991 for unlawful acts and violence during the strike; MEWA filed a second notice of strike on 25 July 1991 for discrimination and union busting involving dismissal of 25 union officers; DOLE certified the second dispute for consolidation, suspending terminations and ordering re-admission without loss of seniority; two illegal dismissal complaints were filed and consolidated with other NLRC cases; NLRC initially upheld some dismissals in 1998 but modified in 2001 to declare strike illegal yet dismissals unjustified, ordering reinstatement without backwages, and further modified in 2002 to include Dizon and Diloy's reinstatement without backwages; separate certiorari petitions to Court of Appeals resulted in conflicting decisions—one upholding dismissals (CA-G.R. SP No. 72480, 30 May 2003) and another ordering backwages (CA-G.R. SP No. 72509, 27 January 2004); Supreme Court denied employees' petitions affirming the dismissal decision (final 2004) and denied MERALCO's petition on technicality (final 2005); writs of execution issued for reinstatement and backwages, with funds garnished, but MERALCO sought and obtained NLRC injunction in 2006 due to conflicts, affirmed by Court of Appeals in 2007.

Petitioners (dismissed employees Frondozo, Perez, Zafra, Vito, Cruz, N. dela Cruz, and Diloy) argued that the Court of Appeals committed grave abuse of discretion by upholding the NLRC's preliminary injunction, as it violated their right to immediate execution of the final and executory NLRC decision affirmed in CA-G.R. SP No. 72509 ordering reinstatement and backwages; they contended the NLRC should have reconciled conflicting Court of Appeals decisions rather than suspending execution, and that the CA-G.R. SP No. 72480 decision should not bar implementation of the favorable judgment; they also claimed the Court of Appeals failed to address issues on reinstatement and release of garnished funds.

Respondent MERALCO argued that the preliminary injunction was properly granted by the NLRC due to conflicting final Court of Appeals decisions—one upholding petitioners' dismissal for illegal strike participation (CA-G.R. SP No. 72480, affirmed by Supreme Court on merits) and another declaring dismissal illegal and ordering backwages (CA-G.R. SP No. 72509, affirmed by Supreme Court on technicality)—making execution inequitable and creating an insurmountable obstacle; it asserted that proceeding with execution would disregard the dismissal-upholding decision, and that suspension was justified under equitable grounds for supervening events affecting final judgments, with no grave abuse by the NLRC as it deferred to judicial power.

• Procedural Issues: - Whether the NLRC committed grave abuse of discretion in granting MERALCO's prayer for preliminary injunction to suspend execution of the final NLRC order for reinstatement and backwages due to conflicting Court of Appeals decisions, and whether the Court of Appeals erred in affirming this suspension.
• Substantive Issues: - Whether the finality of the Court of Appeals decision upholding petitioners' dismissal in CA-G.R. SP No. 72480 (affirmed by Supreme Court on merits) constitutes a supervening event justifying suspension of execution of the conflicting decision in CA-G.R. SP No. 72509 ordering reinstatement and backwages.

• Procedural: - The Supreme Court ruled that the NLRC did not commit grave abuse of discretion in granting the preliminary injunction, as the conflicting final and executory Court of Appeals decisions—particularly the one affirmed on merits upholding dismissal—created a change in circumstances making execution inequitable under instances where writs of execution may be assailed; the Court of Appeals correctly affirmed this, emphasizing the NLRC's lack of power to overrule judicial decisions and the need to defer to courts for reconciliation, thus no capricious or arbitrary action equivalent to lack of jurisdiction occurred.
• Substantive: - The Supreme Court clarified that the decision in CA-G.R. SP No. 72480 (upholding dismissal) predated and was affirmed on merits by earlier Supreme Court resolutions (final 2004), outweighing the later technical denial in G.R. No. 164998 (final 2005) regarding CA-G.R. SP No. 72509; by adopting the CA findings in CA-G.R. SP No. 72480 upon denying petitions for review, the Supreme Court effectively upheld the dismissals for illegal strike participation, resolving the conflict in favor of finality and immutability of judgments, and remanded for execution of those resolutions.

• Grave Abuse of Discretion — Refers to a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction, patent and gross as to amount to evasion of duty or arbitrary action; in this case, the Court applied it to find no such abuse by the NLRC, as suspending execution due to conflicting final judicial decisions was a reasonable deference to judicial power rather than arbitrary conduct.
• Immutability of Final Judgments — Once a judgment becomes final and executory, it is immutable and unalterable, even by the rendering court or higher courts, regardless of perceived errors; here, the Court invoked it to emphasize that the NLRC could not reconcile or modify conflicting Court of Appeals decisions, justifying the injunction to preserve status quo pending judicial resolution.
• Execution Pending Appeal or Supervening Events — Execution of judgments is generally ministerial but may be suspended on equitable grounds for supervening facts materially affecting the obligation, such as changes making execution inequitable; the Court used this to justify quashing alias writs where one final decision upheld dismissal, treating it as a supervening event altering the parties' situation post-finality of the reinstatement order.
• Adoption of Lower Court Findings on Denial of Petition for Review — When the Supreme Court denies a petition for review for failure to show reversible error, it adopts and agrees with the Court of Appeals' findings and conclusions; applied here to confirm that denials in G.R. Nos. 161159 and 161311 meant adoption of CA-G.R. SP No. 72480's upholding of dismissals on merits, outweighing the technical denial in G.R. No. 164998.

• "At the outset, it must be stated that while this Commission has broad powers within its sphere of jurisdiction, it cannot encroach on judicial power which is the exclusive domain of the courts." — NLRC Resolution, highlighting limits of quasi-judicial authority.
• "The term 'grave abuse of discretion' has a specific meaning. An act of a court or tribunal can only be considered as with grave abuse of discretion when such act is done in a 'capricious or whimsical exercise of judgment as is equivalent to lack of jurisdiction.'"
• "When the Court does not find any reversible error in the decision of the CA and denies the petition, there is no need for the Court to fully explain its denial, since it already means that it agrees with and adopts the findings and conclusions of the CA." — From Agoy v. Araneta Center, Inc., explaining adoption of CA rulings.

• Agoy v. Araneta Center, Inc. — Cited as controlling precedent to explain that Supreme Court denial of petition for review adopts Court of Appeals findings, thus affirming the merits of the dismissal-upholding decision in CA-G.R. SP No. 72480.
• Philippine Transmarine Carriers, Inc. v. Legaspi — Referenced illustratively for rules on execution of NLRC decisions under Article 263 of the Labor Code, emphasizing finality after 10 days absent restraining order.
• Mayor Vargas v. Cajucom — Cited as precedent listing grounds for assailing writs of execution, including changes making execution inequitable, applied to justify suspension due to conflicting decisions.
• Malayang Manggagawa ng Stayfast Phils., Inc. v. NLRC — Used to define grave abuse of discretion narrowly, confirming no such abuse by NLRC in suspending proceedings.

• Article 223, Labor Code — Provides for immediate executory nature of reinstatement orders in illegal dismissal cases even pending appeal; relevant as the Court distinguished it from certified cases under Article 263, noting applicability to Labor Arbiter decisions but not overriding conflicts in final judgments here.
• Article 263(i), Labor Code — Mandates that decisions in certified labor disputes by NLRC are final and executory after 10 days, with judicial review via certiorari not staying execution absent restraining order; applied to affirm the NLRC's 2002 order's finality but justified suspension due to supervening judicial decisions.
• Section 1, Rule III, NLRC Manual on Execution of Judgment (as amended by Resolution No. 02-02, 2002) — States execution issues only upon final judgments except for pending appeal provisions; relevant for guiding execution in certified cases like this, supporting injunction where conflicting final court rulings exist.
• 2005 Revised Rules of Procedure of the NLRC — Provides for execution upon entry of judgment in certified cases without distinction between Labor Arbiter and Commission decisions; cited by Court of Appeals but distinguished by Supreme Court in favor of Article 263 for this certified dispute.