G.R. No. 74271. March 31, 1989.
MARINERS POLYTECHNIC SCHOOL and JAIME C. JIMENEZ, petitioners, vs. HON. VICENTE LEOGARDO, JR., Deputy Minister of Labor and Employment, and MARCIAL H. TRACENA, respondents.

FACTS

Respondent Marcial H. Tracena, a classroom teacher, filed money claims against petitioner Mariners Polytechnic School. In a consolidated case, the Labor District Officer ordered Tracena’s reinstatement without loss of seniority rights and payment of back wages from his dismissal up to the end of school year 1977-1978, with a clarifying order stating that if not reinstated by June 1978, back wages would continue until actual reinstatement. This decision became final and executory after affirmance by the Office of the Labor Minister and dismissal of the School’s petition by the Supreme Court. Upon execution, the Regional Director initially computed back wages from 1977 to 1985 but, at the School’s instance, modified the award by limiting back wages to three years without deduction, citing Supreme Court doctrine.
Tracena appealed to the Deputy Minister of Labor, who set aside the Regional Director’s order, ruling that the final judgment could not be substantially altered during execution. The Deputy Minister directed enforcement of the original judgment, which did not contain a three-year limitation. The School then filed this certiorari petition, arguing the Deputy Minister committed grave abuse of discretion by allowing back wages exceeding three years, contrary to established jurisprudence.

ISSUE

Whether the Regional Director and, subsequently, the Deputy Minister of Labor committed grave abuse of discretion in the enforcement of a final and executory judgment by respectively applying and refusing to apply the jurisprudential rule limiting the payment of back wages to three years without deduction or qualification.

RULING

The Supreme Court granted the petition, annulling the Deputy Minister’s order and reinstating the Regional Director’s order limiting back wages to three years. The Court explained that the three-year limitation on back wages, first established in Mercury Drug Co., Inc. v. CIR and solidified in Feati University Faculty Club v. Feati University, is a settled doctrine designed to expedite the execution process. This rule prevents protracted litigation over deductions for wages earned elsewhere during illegal dismissal and ensures employees receive meaningful, timely relief. The doctrine applies to executory judgments requiring computation of monetary benefits, even if the original decision omitted such a limitation. The Court held that the omission must be considered a clerical error, and the three-year limit is deemed written into the judgment. The Deputy Minister’s refusal to apply this uniform doctrine during execution constituted grave abuse of discretion, as it was not within his power to disregard established jurisprudence. The reinstatement of the Regional Director’s order corrects this error and aligns with the policy of unimpeded and speedy execution of labor awards.