GR 160993; (May, 2008) (Digest)
G.R. No. 160993 ; May 20, 2008
TEMIC SEMICONDUCTORS, INC. EMPLOYEES UNION (TSIEU)-FFW, ET AL. vs. FEDERATION OF FREE WORKERS (FFW), ET AL.
FACTS
Temic Semiconductors, Inc. Employees Union (TSIEU), an affiliate of the Federation of Free Workers (FFW), split into two factions following a 1995 strike. Separate elections were held in 1996, resulting in the TSIEU-Dimaano faction and the TSIEU-Robles faction. The FFW governing board, citing a leadership crisis, placed TSIEU under receivership. The TSIEU-Dimaano faction, led by Liza Dimaano, filed a petition before the Bureau of Labor Relations (BLR) Regional Director (RD) to declare the receivership null and void.
The RD granted the petition, ruling the FFW had no authority to place the local union under receivership as their relationship is one of principal and agent. The RD later issued a writ of execution not only to enforce the nullity of the receivership but also to award monetary claims and properties to the TSIEU-Dimaano faction. The BLR Assistant Secretary reversed the RD’s subsequent orders implementing these monetary awards. The Court of Appeals affirmed the BLR Assistant Secretary’s ruling, leading to this petition.
ISSUE
Whether the Court of Appeals erred in affirming the BLR Assistant Secretary’s resolutions which set aside the implementation of the monetary and property awards granted to the TSIEU-Dimaano faction under the writ of execution.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the nature and finality of the RD’s original March 24, 1998 Order. That Order was limited to declaring the receivership null and void; it did not contain any adjudication or award of monetary claims or properties to the union faction. A writ of execution must conform to the judgment it seeks to enforce and cannot vary the terms of the final and executory judgment. The subsequent proceedings before the RD, which aimed to quantify and award these claims, effectively modified the final Order. Such modification is impermissible as a judgment that has attained finality becomes immutable and unalterable.
The Court rejected the argument that these proceedings constituted permissible nunc pro tunc entries meant to correct clerical errors. The claims for money and property were substantive matters not originally included in the judgment. Granting them would prejudice the other party and exceed the scope of the final decision. Furthermore, the claims themselves lacked sufficient evidentiary basis, as the documentary evidence presented was inadequate to substantiate the amounts sought, especially considering the faction’s status during the strike. Therefore, the appellate court correctly ruled that the RD’s orders implementing the monetary awards were null and void.