G.R. No. L-77210 September 19, 1988
MARCOPPER MINING CORPORATION, petitioner, vs. LIWANAG PARAS BRIONES and NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

Petitioner Marcopper Mining Corporation retrenched private respondent Liwanag Paras Briones, a permanent employee, as part of a cost-reduction program. Briones filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, ordering reinstatement with full backwages. The NLRC affirmed this decision. Petitioner’s subsequent petition for certiorari to the Supreme Court was dismissed for lack of merit, and the dismissal became final and executory. A writ of execution was issued. However, before execution, petitioner filed a motion for recomputation with the Labor Arbiter, arguing reinstatement was impossible as Briones’s position had been abolished and she had allegedly obtained other employment. The Labor Arbiter granted the motion, setting aside the final reinstatement order and instead awarding separation pay. The NLRC, on appeal by Briones, reversed the Labor Arbiter and reinstated the original decision for reinstatement with backwages.

ISSUE

The primary issue is whether a final and executory decision of the NLRC can be modified or altered on the ground of supervening events, specifically the alleged abolition of the employee’s position, before its execution.

RULING

The Supreme Court ruled in the negative and upheld the NLRC’s decision. The Court emphasized the doctrine of finality of judgments. A decision that has attained finality becomes immutable and unalterable. Execution must follow as a matter of right, and the issuing court’s duty is purely ministerial. The alleged supervening event—the abolition of the position—was not a valid ground to alter the final judgment. The Court found that the claimed abolition was not a bona fide corporate restructuring but appeared to be a scheme to circumvent the reinstatement order. The original finding of illegal dismissal, which had been affirmed up to the Supreme Court, established Briones’s right to security of tenure. This right cannot be defeated by a post-decision maneuver by the employer. The proper remedy for the employer, if reinstatement is truly impossible, is to reinstate the employee to a substantially equivalent position. The Court modified the backwages to be limited to three years without qualification, in line with prevailing jurisprudence, but upheld the core directive for reinstatement. The Labor Arbiter’s order altering the final judgment was a grave abuse of discretion.