G.R. No. 160474; July 9, 2008
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, INC., Petitioner, vs. ANTONIO T. REUS, Respondent.

FACTS

Antonio Reus was dismissed by PLDT in 1990 for alleged collection shortages. The Labor Arbiter upheld the dismissal but ordered PLDT to pay him indemnity for procedural lapses and “any retirement benefit” under the company plan. Both parties appealed. The NLRC, in a 1993 decision, affirmed the dismissal but modified the award, ordering PLDT to pay Reus benefits under its retirement plan, less the amount of his lost collections. This 1993 NLRC decision became final and executory after both parties’ petitions to the Supreme Court were dismissed.
Subsequent execution proceedings were contentious. A 1998 NLRC resolution, which Reus did not appeal, vacated an initial computation order and remanded the case to determine Reus’s qualification under the plan’s terms. Later, a Labor Arbiter in 1999 granted execution based on the final 1993 NLRC decision, declaring the 1998 NLRC resolution void. PLDT appealed again. While Reus’s petition for mandamus to compel execution was pending at the CA, the NLRC in 2001 annulled the 1999 Arbiter’s order, reiterating the need to first determine qualification under the plan. Reus did not appeal this 2001 order either.

ISSUE

Whether the Court of Appeals erred in granting the writ of mandamus to execute the final and executory 1993 NLRC decision, despite subsequent NLRC resolutions that remanded the case for a determination of entitlement under the retirement plan’s specific terms.

RULING

The Supreme Court affirmed the CA’s decision granting mandamus. The legal logic centers on the immutability of final judgments. The 1993 NLRC decision, which ordered payment of retirement benefits less the shortages, became final and executory in 1995. No subsequent order or resolution could amend or alter its dispositive portion. The Court clarified that the 1993 NLRC award was an “equitable solution” and a clear, unconditional grant, not contingent upon a separate determination of eligibility under the plan’s technical requirements. Subsequent NLRC resolutions in 1998 and 2001, which attempted to impose such a condition by ordering a remand for qualification assessment, were issued without jurisdiction as they sought to modify a judgment that had already attained finality. A final judgment can no longer be disturbed, and execution is a matter of right. Therefore, the CA correctly compelled execution of the 1993 award through mandamus, as the Labor Arbiter had a ministerial duty to enforce it. The garnishment of PLDT’s bond to satisfy the computed award was proper.