G.R. No. 201483 , August 4, 2014
CONRADO A. LIM, Petitioner, vs. HMR PHILIPPINES, INC., TERESA SANTOS-CASTRO, HENRY BUNAG and NELSON CAMILLER, Respondents.

FACTS

Petitioner Conrado A. Lim filed a case for illegal dismissal against respondents. The Labor Arbiter dismissed the complaint. On April 11, 2003, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter, declared Lim illegally dismissed, and ordered his immediate reinstatement. The dispositive portion of the NLRC decision stated that backwages were to be reckoned “from his dismissal on February 3, 2001 up to the promulgation of this Decision.” The Court of Appeals affirmed the NLRC decision with modification, awarding moral and exemplary damages and attorney’s fees. The Supreme Court dismissed the petition assailing the CA decision, and entry of judgment was ordered on July 27, 2007. Lim moved for execution. The NLRC’s Computation and Research Unit computed the total award, calculating backwages from the date of dismissal (February 3, 2001) up to the date of actual reinstatement (October 31, 2007). Respondents opposed, arguing that backwages should be computed only until April 11, 2003 (the date of the NLRC decision promulgation) as stated in the dispositive portion. The Labor Arbiter granted the motion for execution but computed backwages only until April 11, 2003, in accordance with the NLRC decision’s dispositive portion. The NLRC sustained the Labor Arbiter’s computation. The Court of Appeals dismissed Lim’s petition, ruling that the dispositive portion of the final and executory NLRC decision, which limited backwages to the date of promulgation, must prevail over any conflicting statement in the decision’s body.

ISSUE

Whether the Court of Appeals erred in ruling that the computation of backwages should be limited to the date of the NLRC decision’s promulgation (April 11, 2003) as stated in the dispositive portion, rather than up to the date of actual reinstatement.

RULING

The Supreme Court GRANTED the petition. The Court ruled that the body of the NLRC decision explicitly stated that Lim was entitled to full backwages from the time of his illegal dismissal until his actual reinstatement. When there is a conflict between the dispositive portion and the body of the decision, the body prevails if it clearly expresses the intent of the court. The fallo or dispositive portion must be read in conjunction with the decision’s ratio decidendi. The NLRC’s order of immediate reinstatement inherently carries the right to backwages until actual reinstatement, as mandated by Article 279 of the Labor Code. The Court held that the CA erred in strictly applying the rule that the dispositive portion prevails, as the body of the NLRC decision was clear and unambiguous in awarding backwages until actual reinstatement. The case was remanded to the Labor Arbiter for a proper recomputation of backwages from February 3, 2001, until Lim’s actual reinstatement on October 31, 2007, inclusive of the 10% annual increase from 1998 to 2000 and other benefits. The Court also ruled that the monetary awards shall earn legal interest at the rate of 6% per annum from the finality of the decision until full satisfaction.