GR 39742; (June, 1978) (Digest)
G.R. No. L-39742. June 9, 1978.
AIR MANILA, INC., FRANCISCO G. RAMIREZ, JAIME MANZANO, JAMES RAMIREZ and FLORANTE LIMCOLIOC, petitioners, vs. COURT OF INDUSTRIAL RELATIONS (Now National Labor Relations Commission), AIR MANILA LINE PILOTS ASSOCIATION and THE CLERK OF COURT OF THE COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The Air Manila Line Pilots Association (AMILPA) filed a motion before the Supreme Court seeking execution of a final and executory decision dated August 25, 1971, rendered by the Court of Industrial Relations (CIR). That decision declared Air Manila, Inc., et al., guilty of unfair labor practice and ordered the reinstatement of union members with backwages and other monetary benefits. The CIR’s Examining Division subsequently computed the total monetary award at over P10 million, which included items like backwages, overtime pay, night differential, and a substantial sum designated as “by-pass pay.” An order dated March 6, 1973, approved this computation.
However, the National Labor Relations Commission (NLRC), which succeeded the CIR, issued a decision on March 30, 1976, that effectively reconsidered the final 1971 CIR decision. This prompted AMILPA’s motion to set aside the NLRC’s 1976 decision as a nullity and to compel execution of the original 1971 judgment. The petitioners, Air Manila, Inc., et al., opposed the motion, arguing that the NLRC acted within its jurisdiction and that any execution should first be sought with the NLRC as the body of origin.
ISSUE
The primary issue is whether the NLRC’s 1976 decision, which effectively reconsidered the final and executory 1971 CIR decision, is valid, and whether execution of the 1971 decision should be ordered.
RULING
The Supreme Court granted AMILPA’s motion and ordered the execution of the final 1971 CIR decision. The Court ruled that the NLRC’s 1976 decision was a nullity. A final and executory judgment, such as the CIR’s 1971 decision, is immutable and unalterable. The NLRC, as the CIR’s successor, had no jurisdiction to amend, modify, or reverse that final judgment. Its only ministerial duty was to execute it. The Court emphasized that the principle of finality of judgments is a fundamental rule of procedure essential to ending litigation.
On the matter of execution, the Court applied the ruling in Feati University vs. Bautista, which limited backwages to three years without qualification or deduction. Consequently, the Court ordered the immediate execution of the award for backwages, overtime, night differential, and other benefits (Items A, B, C, and E of the computation), amounting to a net total of P4,012,090.42 after deducting one-third for earnings elsewhere. For the “by-pass pay” (Item D), the Court remanded the case to the NLRC for a proper hearing within five days to determine the exact amount due under the 1971 decision, after which a writ of execution for that item should be issued. The resolution underscores that execution is a matter of right for a prevailing party once a judgment becomes final.
