GR 143813; (July, 2003) (Digest)
G.R. No. 143813; July 7, 2003
KING INTEGRATED SECURITY SERVICES, INC., and/or MINA KING, petitioners, vs. GALO S. GATAN, respondent.
FACTS
Respondent Galo S. Gatan filed a complaint for illegal deduction and underpayment of wages against petitioners King Integrated Security Services, Inc. and/or Mina King. The Labor Arbiter ruled in favor of Gatan, ordering payment of wage differentials. The National Labor Relations Commission (NLRC) modified this decision on appeal, deleting claims for a specific period as they were barred by the three-year prescriptive period under Article 291 of the Labor Code. This NLRC Resolution became final and executory.
Consequently, the Labor Arbiter issued an order for the issuance of a writ of execution. Petitioners appealed this execution order to the NLRC, but their appeal was dismissed. They then filed a petition for certiorari with the Court of Appeals, assailing the NLRC’s dismissal. The Court of Appeals dismissed their petition but modified the monetary award.
ISSUE
Whether the Court of Appeals erred in giving due course to and ruling on the merits of the petition for certiorari assailing the order of execution of a final and executory NLRC Resolution.
RULING
The Supreme Court denied the petition, setting aside the assailed Court of Appeals Decision and Resolution. The Court held that an order of execution of a final and executory judgment is not appealable. The principle of finality of judgment dictates that once a decision becomes final, the tribunal’s duty is limited to the ministerial act of ordering its execution. Allowing appeals from such execution orders would lead to interminable litigation, defeating the very purpose of judicial proceedings to settle controversies with finality.
In this case, the NLRC Resolution had attained finality. Therefore, the Labor Arbiter’s order for its execution was not subject to appeal. The Court of Appeals overstepped its jurisdiction by not dismissing the petition outright and instead evaluating the evidence on the merits. The proper course was to dismiss the petition, as the assailed execution order was a mandatory consequence of a final judgment. The Supreme Court emphasized that no additions or modifications can be made to a final judgment except for its execution.