Offer to Pay Monetary Award

In the present case, the Court of Appeals reversed the decision of the National Labor Relations Commission and reinstated the Labor Arbiter’s dismissal of the complaint.

Complainant moved to reconsider the decision of the Court of Appeals, arguing that respondent’s offer to pay the monetary award granted by the National Labor Relations Commission was a compromise agreement that “operates to end litigation and put the case to rest.” The Court of Appeals denied the motion for reconsideration, after which the complainant went to the Supreme Court.

Has respondent’s offer to pay the monetary award of the National Labor Relations Commission constituted a compromise agreement that should have ended the present case?

No.

The Supreme Court held that respondent’s offer to pay the said amount was not in the nature of a compromise agreement.

The Court found that the reason for the offer of payment was complainant’s move to execute the decision of the National Labor Relations Commission, that then left respondent with no recourse but to pay. Such payment was in compliance with the writ of execution issued by the Commission.

The Rules of Procedure of the National Labor Relations Commission provides that its decisions, resolutions or orders shall become final and executory after ten (10) calendar days from receipt thereof. It also states that a writ of execution may be issued motu proprio or on motion, upon a decision or order that has become final and executory. The execution of the final and executory decision or resolution of the Commission shall proceed despite the pendency of a petition for certiorari, unless it is restrained by the proper court.

Since the Court of Appeals issued no temporary restraining order or writ of injunction against the decision of the National Labor Relations Commission, such judgment became final and executory after ten calendar days from its receipt by counsel or party. Consequently, the petitioner moved for the issuance of the writ of execution. Respondent avers that the issuance of the writ of execution and notice of garnishment forced it to pay the monetary award of the National Labor Relations Commission to avoid its bank account being frozen and to prevent the cessation of its operations.

The Supreme Court thus found no intent on the part of the respondent to enter into a compromise agreement to put an end to this dispute. According to the Court, if such was the case, then the respondent could have simply moved to withdraw its petition before the Court of Appeals, specifically manifesting the execution by the parties of a compromise agreement. On the contrary, respondent was found to have pursued its case before the Court of Appeals and vigorously opposed the petition the Supreme Court.

Further reading:

• Quiro–Quiro v. Balagtas Credit Cooperative & Community Development, Inc., G.R. No. 209921, January 13, 2016.