GR 91298; (June, 1990) (Digest)
G.R. No. 91298 June 22, 1990
Corazon Periquet, petitioner, vs. National Labor Relations Commission and The Phil. National Construction Corporation (Formerly Construction Development Corp. of the Phils.), respondents.
FACTS
Corazon Periquet was dismissed by the Construction Development Corporation of the Philippines (CDCP) for alleged willful breach of trust. The Labor Arbiter found her dismissal illegal and ordered her reinstatement with full back wages. This decision was affirmed by the NLRC on August 29, 1980. Subsequently, Periquet and CDCP entered into a compromise agreement wherein she received P14,000.00 as full settlement of her back wages and waived her right to reinstatement. Years later, on March 11, 1989, Periquet filed a motion for the issuance of a writ of execution to claim back wages amounting to P205,207.42, arguing she was only actually reinstated in 1987. The executive labor arbiter granted the motion and garnished the amount from CDCP.
ISSUE
The primary issue is whether the motion for execution filed almost nine years after the NLRC decision became final and executory was timely, and whether the compromise agreement and quitclaim executed by Periquet are valid and binding.
RULING
The Supreme Court denied the petition, affirming the NLRC’s ruling that the motion for execution was time-barred. The Court applied Section 6, Rule 39 of the Revised Rules of Court and Article 224 of the Labor Code, which both prescribe a five-year period within which a final judgment may be executed by motion. Periquet’s motion filed in 1989 was clearly beyond this reglementary period. The Court rejected her argument that the period should be extended due to alleged delays by CDCP, finding instead that it was Periquet who slept on her rights. She voluntarily entered into a compromise agreement, accepted the settlement amount, and even secured other employment, thereby acquiescing to the resolution of her case. The Court upheld the validity of the quitclaim, noting it was voluntarily executed for valuable consideration without any showing of fraud or deceit. Furthermore, the Court ruled that any back pay award, if due, is limited to three years from the date of illegal dismissal and cannot extend to the period she was gainfully employed elsewhere. The petition, raising untenable and inconsistent claims, was dismissed for lack of merit.