G.R. No. 167332 ; February 7, 2011
FILIPINAS PALMOIL PROCESSING, INC. and DENNIS T. VILLAREAL, Petitioners, vs. JOEL P. DEJAPA, represented by his Attorney-in-Fact MYRNA MANZANO, Respondent.

FACTS

On May 27, 1997, respondent Joel P. Dejapa filed a complaint for illegal dismissal and money claims against petitioner Filipinas Palmoil Processing, Inc. (formerly Asian Plantation Phils., Inc.), Dennis T. Villareal, and Tom Madula. The Labor Arbiter dismissed the complaint. The NLRC affirmed this dismissal. The Court of Appeals, in a Decision dated August 29, 2002, reversed the NLRC, finding that respondent was an employee of petitioner company and was illegally dismissed. The CA ordered respondent’s reinstatement with full backwages and other monetary awards, holding petitioner company liable. The CA also found that Tom Madula was not an independent contractor but the company’s Operations Manager and its agent. This CA Decision became final and executory on February 27, 2004, after the Supreme Court denied petitioners’ appeal (G.R. No. 159142).
Respondent moved for execution. The Labor Arbiter issued a Writ of Execution, garnishing a bank deposit of petitioners. Petitioners filed a Motion to Quash the Writ, arguing they should only be liable for reinstatement, not backwages. In an Order dated September 14, 2004, the Labor Arbiter partially granted the motion, ruling that liability for backwages and reinstatement was solely against Tom Madula, while petitioners were solidarily liable only for the rest of the award (except damages). Respondent filed a “Very Urgent Motion for Clarification of Judgment” with the CA, seeking a clarification that petitioner company was solely liable for the entire award as per the final CA Decision.

ISSUE

Whether the Court of Appeals acted within its jurisdiction and correctly granted respondent’s motion for clarification of its final and executory Decision dated August 29, 2002.

RULING

Yes. The Supreme Court affirmed the assailed Resolutions of the Court of Appeals dated December 10, 2004 and February 17, 2005.
The Court held that the CA properly granted the motion for clarification. The clarification did not amend or alter the substance of the final judgment but merely articulated what was necessarily implied from the original decision and basic labor law principles. The CA’s original decision clearly identified petitioner company as the employer and held it liable for the awards. The Labor Arbiter’s subsequent Order, which attempted to reapportion liability to Tom Madula, was a blatant variance from and encroachment upon the final judgment. The grounds invoked by petitioners to quash the writ of execution were improper, as they essentially sought to vary the final judgment.
The Supreme Court emphasized that a final judgment must be executed according to its terms. The CA acted within its equity jurisdiction to clarify its decision and prevent further prolonged litigation, in keeping with the constitutional mandate for the protection of labor. The Court also noted that the doctrine of finality of judgment precludes relitigation and is essential to the effective administration of justice.