GR 165417; (April, 2007) (Digest)
G.R. No. 165417; April 4, 2007
SOCIAL SECURITY SYSTEM, Petitioner, vs. MA. FE F. ISIP, Respondent.
FACTS
The Social Security System (SSS) investigated fraudulent claims processed at its Bacoor, Cavite branch, identifying respondent Ma. Fe F. Isip, the Benefits Section Chief, as a primary suspect. She was formally charged with grave misconduct and related offenses, placed under preventive suspension, and subsequently dismissed by the SSS after being found guilty. The Civil Service Commission affirmed this dismissal. On appeal, the Court of Appeals modified the ruling, finding Isip guilty only of simple misconduct and ordering a six-month suspension without pay, noting her reliance on subordinates’ evaluations and the absence of evidence showing corruption or direct benefit from the fraudulent claims.
The SSS received the Court of Appeals decision on June 30, 2004, but filed its motion for reconsideration on August 13, 2004, well beyond the 15-day reglementary period. The appellate court denied the motion for being filed out of time. The SSS now petitions the Supreme Court, arguing the delay should be overlooked as a mere technicality. Isip, in her comment, not only seeks denial of the petition but also claims entitlement to back wages, asserting she has not been reinstated despite serving her suspension.
ISSUE
Whether the Supreme Court can review the Court of Appeals decision which has become final and executory due to the SSS’s late filing of a motion for reconsideration, and whether Isip is entitled to back wages.
RULING
The petition is denied. The decision of the Court of Appeals has become final and executory. A judgment attains finality by operation of law once the reglementary period to appeal lapses without a perfected appeal. The SSS’s failure to file its motion for reconsideration within the non-extendible 15-day period rendered the appellate court’s decision immutable and unalterable. The doctrine of finality of judgment is grounded on public policy, aiming to end judicial controversies and ensure orderly administration of justice. Exceptions, such as correction of clerical errors or void judgments, do not apply here. Consequently, no court, including the Supreme Court, can exercise appellate jurisdiction to modify the final decision.
Regarding back wages, Isip’s claim is barred by the same finality doctrine. She cannot simultaneously assert the decision’s finality against the SSS and seek its modification in her favor. Furthermore, she has no right to back wages as she was not completely exonerated. Payment of back wages requires a finding of innocence and that the suspension or dismissal was unjustified. The Court of Appeals found her guilty of simple misconduct, thus her suspension was justified.
