G.R. No. L-18270. April 30, 1963.
SAN PABLO OIL FACTORY, INC. and WERNER P. SCHETELIG, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and KAPATIRANG MANGGAGAWA ASSOCIATION (NLU), respondents.

FACTS

The Kapatirang Manggagawa Association filed an unfair labor practice complaint against San Pablo Oil Factory after the company declared a lockout during collective bargaining negotiations. The Court of Industrial Relations (CIR) trial judge initially dismissed the complaint. However, on October 29, 1958, the CIR en banc reversed this dismissal and issued a resolution finding the company guilty of unfair labor practice. This resolution did not award back wages to the locked-out workers.
More than eight months later, on July 6, 1959, the union filed a motion specifically praying for an award of back wages. The CIR granted this motion, amending its October 1958 resolution to include back pay. The company appealed to the Supreme Court, arguing the motion was filed out of time and the CIR had lost jurisdiction. The Supreme Court initially reversed the CIR’s grant of back wages, agreeing the motion was untimely.

ISSUE

The primary issue is whether the union’s motion for back wages, filed over eight months after the CIR’s resolution finding unfair labor practice, was timely filed to allow the CIR to amend its decision.

RULING

The Supreme Court amended its prior decision and affirmed the CIR’s award of back wages. The legal logic hinges on the finality of judgments and the court’s jurisdiction to amend them. A court loses jurisdiction to amend a judgment once it becomes final and executory.
The record revealed a critical fact: although the CIR’s resolution was dated October 29, 1958, the parties only received official notice of it on July 1, 1959. Therefore, the union’s motion filed on July 6, 1959, was made merely five days after notice, not eight months after the resolution’s date. Since the motion was filed before the resolution became final, the CIR retained control and jurisdiction over the case.
The Court further held that the motion for back wages was, in legal effect, a motion for reconsideration or completion of the October 1958 resolution. The original resolution was incomplete because, under Section 15 of the Industrial Peace Act (Republic Act No. 875), a finding of unfair labor practice typically necessitates an award of back wages to the affected employees. The motion sought to correct this omission, which the CIR was empowered to do before its decision attained finality. Thus, the grant of back wages was proper.