G.R. No. 160871 February 6, 2006
TRIAD SECURITY & ALLIED SERVICES, INC. and ANTHONY U. QUE, Petitioners, vs. SILVESTRE ORTEGA, JR., et al., Respondents.

FACTS

Respondents, former security guards of petitioner Triad Security, filed a complaint for illegal dismissal and various monetary claims, including underpayment of wages, overtime pay, and holiday pay. They alleged their compensation was below the minimum wage and that they worked 12-hour daily shifts without proper premium pays. Petitioners countered that respondents were not illegally dismissed but had refused management policies like rotation and refresher courses. The Labor Arbiter ruled in favor of respondents, ordering reinstatement with backwages and awarding substantial money claims. Petitioners failed to appeal this decision, making it final and executory. A writ of execution was issued, leading to the garnishment of petitioner’s funds.
Subsequently, petitioners filed a motion to recompute the awarded money claims, arguing the computations were baseless and their former counsel was not allowed to comment. The Labor Arbiter denied this motion and ordered the release of the garnished funds to respondents. Petitioners appealed to the NLRC, which dismissed their appeal. The Labor Arbiter later issued orders for the release of funds and an alias writ of execution for an unsatisfied balance. Petitioners elevated the case to the Court of Appeals via a petition for certiorari, which was denied. They then filed the present petition before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the Labor Arbiter’s orders and in denying the petition for certiorari, particularly regarding the denial of the motion to recompute the monetary award and the execution proceedings.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the finality of judgments and the nature of execution proceedings. The Labor Arbiter’s decision awarding monetary claims became final and executory due to petitioners’ failure to timely appeal. A final judgment is immutable and unalterable. The subsequent motion to recompute was, in substance, a belated challenge to the merits of the already final monetary award, which is not permitted. Execution is a mere ministerial enforcement of a final judgment.
The Court clarified that while the computation of exact amounts for continuing awards like backwages may be subject to determination even after finality, the motion filed by petitioners did not merely seek a legitimate arithmetic computation. Instead, it sought to relitigate the existence and basis of the liability itself, which had been conclusively settled. The Labor Arbiter and the NLRC correctly treated it as an impermissible attack on a final judgment. The garnishment and release of funds were valid execution steps flowing from the final and executory decision. The Supreme Court, however, modified the computation for accrued backwages, remanding the case to the NLRC for proper reckoning based on applicable wage rates during the specific periods, thereby ensuring the execution conforms precisely to the final judgment’s intent.