Payroll Reinstatement as Exception to the General Rule

"Payroll reinstatement" of the employees, as an exception to the actual reinstatement required by a return to work order, may be allowed, pending final resolution of the validity of their dismissal, in view of a "superseding circumstance," i.e., the final decision of the panel of arbitrators as to the confidential nature of the positions. (G.R. No. 151379; January 14, 2005)