G.R. No. 54243 July 21, 1989
INTERNATIONAL SCHOOL, INC., petitioner, vs. MINISTER OF LABOR AND EMPLOYMENT, LABOR ARBITER ANTONIO TRIA TIRONA, DEPUTY SHERIFF TEODORO VICENTE and INTERNATIONAL SCHOOL ALLIANCE OF EDUCATORS, respondents.

FACTS

Petitioner International School, Inc. and respondent International School Alliance of Educators entered into a Collective Bargaining Agreement (CBA) containing a wage reopening clause. This clause allowed the Alliance to renegotiate salaries if the cost of living index increased by 20% in any year. In 1979, such an increase occurred, triggering renegotiations. The parties reached a deadlock, leading the Minister of Labor to assume jurisdiction. On March 6, 1980, the Minister rendered a Decision granting the Alliance “an increase of 15 percent or P786,643 for salary and P157,332 for allowances or a grand total of P943,980 effective 1 August 1979.” Neither party appealed, making the decision final and executory.
The School then paid its faculty amounts it claimed constituted full compliance. The Alliance, however, moved for execution, alleging a deficiency of P78,180. The School opposed, filing a “Petition for Review and/or Motion to Quash” with the Minister, arguing its payments satisfied the judgment. The Labor Arbiter issued a Writ of Execution. The School then filed this petition, seeking to annul the writ, compel the Minister to decide its pending motion, and halt enforcement.

ISSUE

Whether the Supreme Court should grant the petition for certiorari, prohibition, and mandamus to annul the Writ of Execution and compel action on a motion to quash, considering the finality of the Minister of Labor’s Decision.

RULING

The petition is dismissed. The core legal principle is the immutability of final judgments. The Minister of Labor’s Decision of March 6, 1980, became final after neither party appealed or moved for reconsideration. Execution must strictly conform to the dispositive portion of a final judgment. The School’s attempt to seek a re-computation or interpretation through a “Motion to Quash” filed after finality is impermissible. A party cannot, after a judgment becomes final, seek its amendment or modification through such a motion; the proper remedy was a timely appeal. The Minister of Labor cannot be compelled via mandamus to act on a motion whose purpose is to alter a final and executory order. The writs of certiorari and prohibition are also unavailing as there was no grave abuse of discretion in issuing the Writ of Execution to enforce the final judgment. The School is directed to pay the adjudged deficiency. The ruling emphasizes that final judgments are the law of the case and must be respected to ensure stability in judicial and quasi-judicial proceedings.