GR 147941; (March, 2005) (Digest)
G.R. No. 147941 & G.R. No. 147981. March 16, 2005
NESTOR V. BLANCO, Petitioner, vs. PHILIPPINE AUTOMOTIVE MFG. CORP., Respondent.
(Consolidated with G.R. No. 147981)
FACTS
Nestor Blanco filed a complaint for illegal dismissal against Philippine Automotive Manufacturing Corporation (PAMCOR). The Labor Arbiter ruled in his favor, ordering his reinstatement and payment of backwages amounting to ₱24,398.40. The National Labor Relations Commission (NLRC) affirmed the decision with the modification of deleting the attorney’s fees. This NLRC Decision became final and executory. PAMCOR complied by paying the monetary award and reinstating Blanco as a probationary machinist effective August 1, 1997.
Subsequently, Blanco filed a motion with the Labor Arbiter for a recomputation of his backwages to cover the period from the promulgation of the Arbiter’s decision until his actual reinstatement, and another motion praying for his reinstatement as a regular employee. The Labor Arbiter granted both motions, ordering PAMCOR to pay additional backwages and to reinstate Blanco as a regular machinist. PAMCOR appealed to the NLRC, which reversed the Arbiter’s order. Blanco’s petition for certiorari was dismissed by the Court of Appeals.
ISSUE
Whether the Labor Arbiter had jurisdiction to modify the final and executory NLRC Decision by ordering additional backwages and a change in Blanco’s employment status.
RULING
The Supreme Court denied both petitions and affirmed the Court of Appeals. The core legal principle applied is the doctrine of finality of judgment. The NLRC Decision dated July 18, 1996, which ordered Blanco’s reinstatement and payment of a specific sum as backwages, had attained finality upon PAMCOR’s full compliance. A final and executory judgment is immutable and unalterable; it can no longer be modified in any respect, even for perceived errors, except for clerical errors or the execution of its terms. The Labor Arbiter, therefore, overstepped his jurisdiction when he issued the subsequent order altering the definitive judgment by awarding additional backwages and declaring Blanco a regular employee. The Court emphasized that to allow such modifications would defeat the very purpose of judicial finality and lead to endless litigation. Consequently, the Labor Arbiter’s assailed order was a nullity for having been issued without jurisdiction.