G.R. No. 102876 March 4, 1997
BATAAN SHIPYARD AND ENGINEERING CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, NAFLU and PASTOR, ABAQUITA, ET AL., respondents.

FACTS

Petitioner Bataan Shipyard and Engineering Co., Inc. (BASECO) retrenched 285 employees in 1982. The Labor Arbiter declared the retrenchment valid but found BASECO guilty of unfair labor practice for discriminatory selection, ordering it to pay separation pay and six months’ backwages. BASECO appealed to the NLRC, which affirmed the decision in 1985. This NLRC resolution became final and executory in 1988 after the Supreme Court dismissed BASECO’s petition. The workers then moved for a writ of execution to enforce the monetary award.
BASECO opposed the execution, claiming it had already partially satisfied the judgment by paying separation benefits to some workers during the retrenchment process. It argued these payments should be deducted from the total award. The NLRC, however, issued resolutions on July 19 and October 30, 1991, granting the writ of execution for the full amount without deduction. BASECO filed this certiorari petition, alleging the NLRC committed grave abuse of discretion.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in issuing a writ of execution for the full monetary award without deducting alleged prior partial payments made by BASECO.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the NLRC. The legal logic is anchored on the finality of judgments and the respect accorded to factual findings of quasi-judicial agencies. The NLRC’s 1985 resolution, which affirmed the Labor Arbiter’s decision, had long become final and executory. A final judgment is immutable and unalterable; its execution becomes a ministerial duty of the court. BASECO’s attempt to reopen the case and deduct alleged prior payments constituted a collateral attack on this final judgment, which is impermissible.
Furthermore, the NLRC’s factual finding that no partial payment had been made was accorded finality. The Court emphasized that factual findings of agencies like the NLRC are generally binding, especially when supported by evidence. BASECO failed to substantiate its claim of prior payment with conclusive proof, such as affidavits of satisfaction, quitclaims, or receipts from the employees. Without such evidence, the claim remained a bare allegation. The Court also highlighted the constitutional policy to protect workers’ welfare, noting the retrenched employees had waited years for their rightful benefits. Thus, the NLRC acted within its jurisdiction in ordering the execution of the full award.