The Court of Appeals (CA) has upheld the ruling ordering GMA Network Inc. to pay P240.6 million to 500 of its employees after the network was found guilty of unfair labor practice in connection with hazard pay during the COVID-19 pandemic.
In an 11-page decision penned by Associate Justice Carlito Calpatura, the CA Fifth Division dismissed GMA Network’s petition seeking to overturn the National Labor Relations Commission (NLRC) ruling that affirmed the labor arbiter’s issuance of a writ of execution for the collection of the award.
The appellate court also upheld the NLRC’s ruling affirming the labor arbiter’s Sept. 17, 2024 order denying GMA Network’s motion to quash the writ of execution.
The CA found no grave abuse of discretion on the part of the NLRC in ruling against the network.
“All told, We find that the NLRC did not gravely abuse its discretion in rendering the assailed Decision and Resolution, considering that it based its conclusions on substantial evidence, and on relevant laws and jurisprudence,” the CA said.
The case stemmed from a complaint filed by the GMA Employees Union (GMAEU) and 500 of its members against the network for unfair labor practice, nonpayment of hazard pay, moral damages and attorney’s fees.
In a Dec. 22, 2022 decision, labor arbiter Irene Castro de Quiroz found GMA Network guilty of unfair labor practice and ordered it to pay hazard pay and attorney’s fees.
The ruling covered the period when community quarantine measures were imposed during the pandemic.
The NLRC later denied GMA Network’s appeal and motion for reconsideration in its June 22, 2023 decision and Oct. 16, 2023 resolution.
The NLRC subsequently issued an entry of judgment declaring the resolution final and executory on Oct. 30, 2023.
GMAEU then sought the execution and recomputation of the award, covering the period from March 17, 2020 to March 31, 2021.
The union argued that the employees’ entitlement to hazard pay should continue until July 20, 2023 because President Ferdinand Marcos Jr. lifted the COVID-19 state of public health emergency only on June 21, 2023.
The employees initially sought execution of an award amounting to P66.5 million in hazard pay and attorney’s fees for the March 17, 2020 to March 31, 2021 period.
They also sought additional hazard pay and 10% attorney’s fees for April 1, 2021 to July 20, 2023.
On March 4, 2024, the labor arbiter granted the union’s motion for execution and recomputation.
With no restraining or injunctive order from the CA or Supreme Court, the labor arbiter issued a writ of execution on July 8, 2024 directing the sheriff to collect P240,626,650 from GMA Network as the employees’ judgment award.
The writ also included P2.4 million in execution fees and P401,044.42 in deposit fees under the NLRC Manual on Execution.
GMA Network moved to quash the writ by arguing that it was not given notice of the final recomputation of the judgment award or an opportunity to comment before the writ was issued.
The labor arbiter denied the motion, prompting GMA Network to seek relief from the NLRC, which also ruled against the network.
The CA, however, found the writ validly issued.
It said the labor arbiter was not required to issue a separate order approving the actual recomputation made by the NLRC’s Computation and Examination Unit before issuing the writ of execution.
The appellate court cited Section 1, Rule XI of the 2025 NLRC Rules of Procedure, which provides that a labor arbiter “shall motu proprio issue a writ of execution” once a decision or order becomes final and executory.
The CA also rejected GMA Network’s claim that it was denied due process, noting that the network had been given an opportunity to be heard during the pre-execution conference before the labor arbiter.
“The Court has consistently held that the essence of due process is the opportunity to be heard. In other words, there is no denial of the right to due process if there was an opportunity for the parties to defend their interest,” the CA said.#