GR 161777; (May, 2008) (Digest)
G.R. No. 161777 ; May 7, 2008
DOMINIC GRIFFITH vs. ANGELITO ESTUR, ET AL.
FACTS
Respondents Angelito Estur, Juan Ofalsa, and Rolando Ereve filed a complaint for illegal dismissal and monetary claims against Lincoln Gerald, Inc. and its Vice President for Southeast Asia Operations, petitioner Dominic Griffith. On October 4, 1999, Labor Arbiter Vicente Layawen rendered a decision ordering Lincoln and Griffith to pay the complainants’ monetary awards. Lincoln’s appeal was not perfected, rendering the decision final and executory on July 6, 2001. Subsequently, an alias writ of execution was issued against “Lincoln Gerald, Inc. and/or Dominic G. Griffith.”
Petitioner Griffith moved to quash the writ, arguing he was not personally liable as a corporate officer acting in good faith and that the writ’s inclusion of an execution fee unlawfully modified the final judgment. He also claimed he was no longer connected with Lincoln as of September 17, 1997. The Labor Arbiter and the NLRC denied his motion. The Court of Appeals dismissed his petition for certiorari, prompting this petition for review.
ISSUE
Whether the Court of Appeals erred in ruling that the NLRC did not commit grave abuse of discretion in upholding the alias writ of execution against petitioner Griffith.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle is that a final and executory judgment can no longer be altered and must be enforced. The Labor Arbiter’s 1999 decision, which held Lincoln and Griffith solidarily liable, had attained finality. A writ of execution must conform strictly to this dispositive portion. The alias writ issued against “Lincoln Gerald, Inc. and/or Dominic G. Griffith” did not modify the judgment but merely implemented its terms, which already imposed solidary liability. Griffith’s personal liability, as determined in the final decision, could no longer be collaterally attacked through a motion to quash the writ.
Furthermore, the inclusion of the execution fee did not constitute an improper modification. The NLRC Sheriff Manual explicitly authorizes the collection of such fees from the losing party. This is a procedural incident of execution, not a substantive alteration of the final award. Griffith’s belated claim of having severed ties with the corporation was unsupported by evidence and irrelevant, as the final judgment had already established his liability. The Court emphasized that execution is the fruit and end of the suit, and a writ that conforms to a final judgment is valid.