GR 166136; (August, 2006) (Digest)
G.R. No. 166136 , August 18, 2006
MARIO DANILO B. VILLAFLORES, Petitioner, vs. RAM SYSTEM SERVICES, INC. and ROGELIO U. YAP, Respondents.
FACTS
Petitioner Mario Danilo Villaflores and his wife filed complaints for illegal dismissal and monetary benefits against RAM System Services, Inc. (RSSI) and its President, Rogelio Yap. RSSI countered that Mario was not an employee but a treasurer, incorporator, and partner of the corporation. The Labor Arbiter and the NLRC dismissed the complaints, ruling that no employer-employee relationship existed. On certiorari, the Court of Appeals (16th Division) reversed this in CA-G.R. SP No. 58836, declaring the termination illegal and ordering reinstatement with backwages. This decision became final.
During execution before the Labor Arbiter, a dispute arose over the computation of Mario’s backwages, specifically his correct monthly salary. Mario claimed it was P20,000, while RSSI contested this. The Labor Arbiter and the NLRC ruled on the computation. Mario then filed a petition for certiorari with the Court of Appeals (9th Division), assailing these execution orders.
ISSUE
Whether the Court of Appeals (9th Division) had jurisdiction to entertain the petition for certiorari challenging the Labor Arbiter’s and NLRC’s orders issued in the execution of a final and executory judgment.
RULING
The Supreme Court granted the petition, ruling that the Court of Appeals (9th Division) had no jurisdiction. The legal logic is anchored on the doctrine of finality of judgments. The decision in CA-G.R. SP No. 58836, which declared the illegal dismissal and awarded reinstatement and backwages, had already attained finality. Consequently, the Labor Arbiter’s role was purely ministerial—to execute the judgment according to its terms. Any orders issued during such execution proceedings are not appealable, nor are they subject to a petition for certiorari under Rule 65, as they involve the enforcement of a final judgment, not the exercise of judicial discretion. A writ of certiorari is only available against acts rendered without or in excess of jurisdiction or with grave abuse of discretion. The Labor Arbiter, in implementing the final CA decision, was not performing a judicial function but a ministerial one. Therefore, the proper remedy for any party aggrieved by the execution, such as a dispute over the computation of the monetary award, was not a new petition before a different division of the CA, but a motion for clarification directed to the same division (the 16th Division) that rendered the now-final decision. The Supreme Court set aside the challenged CA decision for lack of jurisdiction.