GR 98239; (April, 1996) (Digest)
G.R. No. 98239 . April 25, 1996.
CONSUELO VALDERRAMA, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, FIRST DIVISION AND MARIA ANDREA SAAVEDRA, respondents.
FACTS
Maria Andrea Saavedra filed a complaint for illegal dismissal against COMMODEX (Phils.), Inc. and its officers, including petitioner Consuelo Valderrama as owner. The Labor Arbiter found Saavedra illegally dismissed due to pregnancy, not redundancy, and ordered “respondent company” to reinstate her with backwages and damages. The decision became final. A writ of execution was returned unsatisfied as COMMODEX had ceased operations, and the individual officers, including Valderrama, argued they were not liable since only the company was named in the dispositive portion.
Saavedra filed a Motion for Clarification, praying that the dispositive part be corrected to hold the respondents jointly and severally liable, arguing this was a clerical error as the decision’s body implicated all respondents. The Labor Arbiter granted the motion, and evidence showed Valderrama owned 1,993 of the corporation’s 2,000 shares and served as its Chairman and President. The Arbiter subsequently held Valderrama personally liable for the monetary awards. The NLRC affirmed this order.
ISSUE
Whether the Labor Arbiter could, after finality of the decision, clarify the dispositive portion to hold petitioner personally liable.
RULING
Yes. The Supreme Court dismissed the petition, upholding the clarification. The rule on the immutability of final judgments admits exceptions where subsequent facts render execution impossible or unjust. Here, execution against the corporate entity was impossible as it had ceased operations without undergoing bankruptcy proceedings. Modification was thus appropriate to serve substantial justice.
The clarification did not constitute a substantive amendment but a correction of a clerical error to align the dispositive portion with the decision’s body, which had found the individual respondents liable. Furthermore, technical rules of procedure are not strictly applied in labor cases to effectuate the constitutional mandate of protecting labor. Overlooking procedural lapses is justified to promote substantial justice. Petitioner, as the controlling stockholder and president, could be held personally liable under the doctrine that corporate officers may be held accountable for corporate debts arising from illegal acts, such as the discriminatory dismissal based on pregnancy. The ruling ensures the worker’s rightful award is not rendered ineffectual by corporate dissolution.