GR 120931; (October, 2000) (Digest)
G.R. No. 120931; October 20, 2000
TAG FIBERS, INC. and RAFAEL ZULUAGA, JR., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER REYNOSO A. BELARMINO, ICARDO ABANES, et al., respondents.
FACTS
Petitioner Tag Fibers, Inc. terminated the employment of respondents in February 1983 due to alleged company losses. The respondents were re-hired shortly thereafter as piece-rate workers. In 1983, after the respondents filed a complaint for wage violations, petitioners prohibited them from working. The respondents subsequently filed a complaint for illegal dismissal. On January 11, 1985, Labor Arbiter Felipe T. Garduque III rendered a decision ordering the reinstatement of the complainants to their former positions and the payment of a monetary award. This decision was affirmed by the NLRC in 1986 and became final after the Supreme Court dismissed the petitioners’ certiorari petition in 1987.
During execution proceedings years later, the petitioners paid the monetary award but refused reinstatement. In 1993, Labor Arbiter Reynoso A. Belarmino, citing strained relations, issued a resolution granting the respondents separation pay in lieu of reinstatement, covering a period from 1983 to 1993. The NLRC later modified this award. The petitioners challenged these subsequent resolutions, arguing that the Labor Arbiter and NLRC had no authority to modify the final 1985 judgment which had ordered reinstatement.
ISSUE
Whether the Labor Arbiter and the NLRC acted without jurisdiction in issuing resolutions that modified the final and executory judgment in the illegal dismissal case.
RULING
The Supreme Court granted the petition and set aside the assailed NLRC resolutions. The Court held that the January 11, 1985 decision of Labor Arbiter Garduque, as affirmed by the NLRC and the Supreme Court, had long become final and executory. Under Rule 39, Section 6 of the 1964 Revised Rules of Court, applicable suppletorily to labor cases, a judgment may be executed on motion within five years from its finality. The Labor Arbiter’s authority to execute such a final judgment is purely ministerial.
The conference set by Labor Arbiter Belarmino in 1993 and the subsequent resolutions granting separation pay effectively modified the substance of the final 1985 judgment, which had specifically ordered reinstatement. The NLRC, in affirming this modification, likewise acted without jurisdiction. A final and executory judgment cannot be altered, and the convenience of a party or the passage of time does not revive jurisdiction over it. The attempt to convert the relief from reinstatement to separation pay constituted an unauthorized substantive amendment to a judgment that was already immutable.