GR 101723; (May, 2000) (Digest)
G.R. No. 101723 May 11, 2000
INDUSTRIAL MANAGEMENT INTERNATIONAL DEVELOPMENT CORP. (INIMACO), petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and ENRIQUE SULIT, ET AL., respondents.
FACTS
Private respondents, former employees, filed a complaint for separation pay and unpaid wages against several entities, including petitioner INIMACO. In a 1987 Decision, Labor Arbiter Bonifacio B. Tumamak ordered the respondents, including INIMACO, to pay the complainants specific monetary awards, stating they were to pay the aggregate sum. The decision became final and executory. The Labor Arbiter later issued an Alias Writ of Execution, which used the term “and/or” between the named respondents (e.g., “Antonio Gonzales/INIMACO and/or Filipinas Carbon…”), effectively enforcing the judgment against them in a solidary manner.
INIMACO moved to quash the alias writ, arguing it unlawfully altered the final decision by converting the respondents’ liability from joint to solidary, as the dispositive portion did not contain the word “solidary.” The Labor Arbiter and, on appeal, the NLRC, denied INIMACO’s motion. The NLRC upheld the writ, adopting a liberal approach in labor proceedings to grant the complainants’ prayers. INIMACO then filed this petition for certiorari.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in upholding the Alias Writ of Execution that imposed solidary liability on the respondents, thereby varying the terms of the final and executory decision which ordered only joint liability.
RULING
Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition, declaring the NLRC’s resolution null and void. The Court emphasized the doctrine of immutability of final judgments. Once a decision becomes final and executory, it is removed from the jurisdiction of the court or tribunal to alter or amend it. The Labor Arbiter’s 1987 Decision had become final. Its dispositive portion ordered the respondents to pay the awards without specifying solidary liability.
Under Article 1207 of the Civil Code, a joint obligation is presumed when the law or the judgment does not expressly state solidarity. The Alias Writ of Execution, by using “and/or,” effectively changed the nature of the obligation from joint to solidary. An order of execution that varies the tenor of a final judgment is a nullity. The NLRC’s liberal construction in favor of labor cannot be used to justify an execution that substantively alters a final decision. Thus, the liability of the respondents, including INIMACO, remains merely joint. INIMACO’s payment of its proportionate share constitutes full satisfaction of its liability under the judgment.