G.R. No. 88864; January 17, 1990
PACIFIC MILLS, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION AND/OR CITY SHERIFF OF MANILA, respondents.

FACTS

This case involves the execution of a final and executory judgment of the National Labor Relations Commission (NLRC). In a prior case, G.R. No. 79535, the Supreme Court dismissed Pacific Mills, Inc.’s petition on August 3, 1988, resulting in the finality of the NLRC decision which upheld a labor arbiter’s award in favor of the private respondents. Following the entry of judgment, the NLRC proceeded with execution and computed the total monetary award at P680,037.30. It subsequently issued a partial writ of execution for P655,527.30 on May 5, 1989.
On May 9, 1989, petitioner Pacific Mills, Inc. filed a motion to stay the execution, citing several supervening events that allegedly affected the correctness of the award’s computation. These events included: the alleged failure to properly consider each complainant’s length of service for separation pay; the non-consideration of wage exemptions granted to the company; the inclusion of awards to individuals who had already been recalled to duty, separately paid, or paid regardless of the case’s outcome; and the alleged foreclosure or attachment of the company’s capital assets by other creditors. The NLRC, however, denied the motion and ordered the immediate implementation of the writ in its June 21, 1989 order.

ISSUE

Whether the NLRC committed grave abuse of discretion in refusing to stay the execution of its final judgment and in not considering the alleged supervening events raised by the petitioner.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition, setting aside the NLRC’s questioned orders. The legal logic is anchored on the principle that while a judgment becomes final and executory, its execution must conform to what is decreed in the dispositive part. The Court emphasized that supervening events, if proven, can affect the proper implementation or computation of a final award. The events raised by the petitioner—specifically, the correct length of service for separation pay, applicable wage exemptions, and prior payments made to some awardees—are matters that directly pertain to the accurate computation of the monetary judgment. If these allegations are true, executing the award without adjusting for these facts would result in enforcing an amount not actually owed under the terms of the final decision itself.
The Court ruled it was the NLRC’s duty to inquire into the correctness of the execution in light of these supervening events to prevent a clear error in the enforcement process. The denial of an opportunity for the petitioner to present evidence on these matters constituted a denial of due process and a grave abuse of discretion tantamount to excess of jurisdiction. The NLRC was thus directed to immediately hear the petitioner’s evidence on the supervening events, recompute the award accordingly, and then ensure the prompt satisfaction of the corrected judgment.