GR 79106; (April, 1989) (Digest)
G.R. No. 79106 April 10, 1989
CHRISTIAN LITERATURE CRUSADE, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and LOIDA DEL ROSARIO, respondents.
FACTS
Private respondent Loida del Rosario was dismissed by petitioner Christian Literature Crusade in 1976. The Labor Arbiter, in a 1982 decision, ordered her reinstatement with three years of backwages. The backwages were paid in 1982, but the reinstatement was not effected despite several writs of execution. In 1987, the Labor Arbiter issued a new writ, ordering reinstatement and awarding additional backwages from 1982 onward, amounting to over P84,000. The petitioner challenged this 1987 writ, arguing it modified the final 1982 judgment which limited backwages to three years.
ISSUE
Whether the Labor Arbiter, in the 1987 writ of execution, could validly award backwages beyond the three-year period stipulated in the final 1982 decision.
RULING
No. The Supreme Court ruled that the 1987 writ of execution was a grave abuse of discretion for altering the final and executory 1982 judgment. The legal logic is anchored on the doctrine of immutability of final judgments. A decision that has attained finality becomes immutable and unalterable; it can no longer be modified in any respect, even for error correction. The 1982 decision explicitly granted backwages for a period of three years without qualification. This specific award had already been satisfied in 1982. The subsequent 1987 writ, which computed backwages from 1982 to 1987, effectively extended the period of the award and increased the monetary liability. This constituted an unauthorized amendment of a final judgment. The proper recourse for the employee, whose reinstatement was unjustly delayed, was not to seek a recomputation of backwages but to file a motion to cite the employer in contempt for defying the reinstatement order. The Court distinguished cases where backwages were awarded until actual reinstatement, noting those involved different procedural postures, such as return-to-work orders or the implementation of specific, previously resolved mandates, not the alteration of a final monetary award. Consequently, the 1987 writ was set aside insofar as it granted additional backwages, and the employee was ordered to refund the excess amount received. The order for reinstatement, however, remained valid and enforceable.