GR L 25320; (November 1975) (Digest)
G.R. No. L-25320 November 28, 1975
UNITED STATES LINES CO., petitioner, vs. ASSOCIATED WATCHMEN AND SECURITY UNION (PTGWO), et al., and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The Court of Industrial Relations (CIR) ordered petitioner United States Lines Co. to reinstate eleven dismissed watchmen with back wages. This decision was affirmed by the Supreme Court. Upon remand, a court examiner computed back wages up to August 22, 1963, the deadline for reinstatement. The parties subsequently negotiated a settlement; petitioner paid the claims, and the respondents, assisted by counsel, executed receipts and releases. Based on a joint motion, the CIR issued an order on March 13, 1964, dismissing the case for satisfaction of judgment.
Over a year later, on May 27, 1965, the respondents, through new counsel, filed a motion to set aside the dismissal and reopen the case. They sought a recomputation of back wages, arguing the original computation was incomplete as it only covered wages up to August 22, 1963, and did not include various premium pays. The CIR granted the motion to reopen for recomputation of basic back wages but denied the new claims for premium pays.
ISSUE
Whether the CIR could legally reopen the case after it had been dismissed upon satisfaction of judgment.
RULING
No. The Supreme Court reversed the CIR’s order reopening the case. The legal logic hinges on the interpretation of Section 17 of Commonwealth Act 103, which governs the modification of CIR awards. The provision allows reopening only during the effectiveness of an award and solely upon grounds that arose after the decision was rendered. It does not permit reopening based on grounds that were available during the original proceedings but were not raised, or on issues already directly or impliedly litigated and settled.
Here, the order of reinstatement with back wages had already been fully satisfied, as evidenced by the payments, releases, and the dismissal order. The respondents’ claim for a more comprehensive computation of back wages, including the period covered, was a matter that could and should have been addressed during the original computation and settlement process. Allowing a reopening over a year after final dismissal, based on grounds existing at the time of settlement, would sanction endless litigation and violate the principle of finality of judgments. The CIR thus acted in excess of its jurisdiction.