GR 160876; (January, 2008) (Digest)
G.R. No. 160876 ; January 18, 2008
AZUCENA MAGALLANES, EVELYN BACOLOD and HEIRS OF JUDITH COTECSON, petitioners, vs. SUN YAT SEN ELEMENTARY SCHOOL, PAZ GO, ELENA CUBILLAN, WILLY ANG GAN TENG, BENITO ANG, and TEOTIMO TAN, respondents.
FACTS
Petitioners, teachers at Sun Yat Sen Elementary School, were illegally dismissed in 1994. The Labor Arbiter ruled in their favor, a decision later reversed by the NLRC. On certiorari, the Court of Appeals (Special Sixteenth Division) in CA-G.R. SP No. 50531 reinstated the Labor Arbiter’s finding of illegal dismissal but modified the award, granting separation pay and backwages computed from dismissal until the promulgation of its Decision on October 28, 1999. This CA Decision became final and executory in 2000.
Subsequently, upon petitioners’ motion for execution, the Labor Arbiter computed monetary awards from June 1994 to October 28, 1999, per the final CA Decision. Respondents appealed this computation to the NLRC, which modified it by limiting the computation period only up to June 20, 1995, thereby drastically reducing the award. Petitioners then filed a petition for certiorari with the Court of Appeals (Seventh Division), docketed as CA-G.R. SP No. 67068, challenging the NLRC’s order.
ISSUE
Did the NLRC commit grave abuse of discretion in modifying the final and executory monetary award as decreed by the Court of Appeals?
RULING
Yes. The Supreme Court ruled that the NLRC committed grave abuse of discretion. The legal logic is anchored on the doctrine of finality and immutability of judgments. The Court of Appeals’ Decision in CA-G.R. SP No. 50531, which specifically mandated the computation of backwages up to October 28, 1999, had long become final and executory. A final judgment can no longer be altered, amended, or modified in any substantial way by any court or quasi-judicial agency. The NLRC, as a quasi-judicial body, exceeded its jurisdiction when it unilaterally shortened the computation period to June 20, 1995, thereby effectively amending a final judgment of a superior court. This act violated a fundamental principle that prevents endless litigation and ensures stability in judicial determinations. Consequently, the NLRC’s Order was declared void. The Supreme Court reinstated the Labor Arbiter’s computation, which faithfully implemented the final CA Decision.