GR 173908; (February, 2008) (Digest)
G.R. No. 173908 ; February 26, 2008
Eleanor C. Magalang, petitioner, vs. Court of Appeals (Former Fourth Division), National Labor Relations Commission (3rd Division) and Suyen Corporation, respondents.
FACTS
Petitioner Eleanor C. Magalang, an Account Executive and acting union president of Suyen Corporation, was dismissed on October 17, 1998, for allegedly falsifying a company request form for transportation allowance reimbursement. She filed an illegal dismissal complaint. The Labor Arbiter dismissed her complaint, but the NLRC, on appeal, declared her dismissal illegal. However, the NLRC denied her backwages, finding she was not entirely faultless for proceeding to her assignment from her residence instead of the reported office origin. Both parties filed motions for reconsideration.
The procedural history became complex. The NLRC denied Magalang’s motion, prompting her to file a petition for certiorari with the Court of Appeals, docketed as CA-G.R. SP No. 75185. The NLRC later also denied Suyen Corporation’s motion, leading the company to file its own certiorari petition, docketed as CA-G.R. SP No. 79408. The Ninth Division of the CA, in CA-G.R. SP No. 75185, affirmed the NLRC’s finding of illegal dismissal but modified the decision by awarding Magalang full backwages. This decision became final and executory. Subsequently, the Fourth Division of the CA, in CA-G.R. SP No. 79408, rendered a decision that merely affirmed the original NLRC ruling without the backwages award, creating an inconsistency.
ISSUE
Whether the Court of Appeals’ Fourth Division committed reversible error in rendering a decision inconsistent with a final and executory judgment issued by a coordinate division of the same court.
RULING
The Supreme Court granted the petition. The legal logic centers on the doctrines of finality of judgment and judicial stability. The Ninth Division’s decision in CA-G.R. SP No. 75185, which awarded backwages, had already attained finality as no appeal was interposed. A final and executory judgment is immutable; the court loses jurisdiction over it, and not even a coordinate court can review or alter it. This ensures an end to litigation and upholds the rule of law.
Furthermore, the Court emphasized the policy of judicial stability. The various divisions of the Court of Appeals are coordinate courts. One division should not interfere with or overturn the final decision of another, as doing so would cause confusion and hinder the administration of justice. The conflict arose because the two related petitions were not consolidated. To resolve the inconsistency and give effect to the final judgment, the Supreme Court modified the Fourth Division’s decision to include the award of full backwages, thereby making it consistent with the Ninth Division’s final ruling.