Prince Transport v. Garcia, January 12, 2011

Facts:
 
Prince Transport, Inc. (PTI), is a company engaged in the business of transporting passengers by land; respondents were hired either as drivers, conductors, mechanics or inspectors, except for respondent Diosdado Garcia (Garcia), who was assigned as Operations Manager. Sometime in October 2007 the commissions received by the respondents were reduced to 7 to 9% from 8 to 10%. This led respondents and other employees of PTI to hold a series of meetings to discuss the protection of their interests as employees. Ranato Claros, president of PTI, made known to Garcia his objections to the formation of a union and in order to block the continued formation of the union, PTI caused the transfer of all union members and sympathizers to one of its sub-companies, Lubas Transport (Lubas).
 
The business of Lubas deteriorated because of the refusal of PTI to maintain and repair the units being used therein, which resulted in the virtual stoppage of its operations and respondents' loss of employment. Hence, the respondent-employees filed complaints against PTI for illegal dismissal and unfair labor practice. PTI contended that it has nothing to do with the management and operations of Lubas as well as the control and supervision of the latter's employees.
 
​Issue:
Whether or not the order to reinstate respondents was valid considering that the issue of reinstatement was never brought up before the CA and respondents never questioned the award of separation pay?
 
 Held:
YES. It is clear from the complaints filed by respondents that they are seeking reinstatement. Section 2 (c), Rule 7 of the Rules of Court provides that a pleading shall specify the relief sought, but may add a general prayer for such further or other reliefs as may be deemed just and equitable. Under this rule, a court can grant the relief warranted by the allegation and the proof even if it is not specifically sought by the injured party; the inclusion of a general prayer may justify the grant of a remedy different from or together with the specific remedy sought, if the facts alleged in the complaint and the evidence introduced so warrant. The general prayer is broad enough “to justify extension of a remedy different from or together with the specific remedy sought.”
 
Even without the prayer for a specific remedy, proper relief may be granted by the court if the facts alleged in the complaint and the evidence introduced so warrant. The court shall grant relief warranted by the allegations and the proof even if no such relief is prayed for. The prayer in the complaint for other reliefs equitable and just in the premises justifies the grant of a relief not otherwise specifically prayed for. In the instant case, aside from their specific prayer for reinstatement, respondents, in their separate complaints, prayed for such reliefs which are deemed just and equitable