Marcopper Mining Corporation v. Liwanag Paras Briones
REITERATIONFacts
The Antecedents: Private respondent Liwanag Paras Briones was hired as a probationary employee by petitioner Marcopper Mining Corporation and later extended permanent employment. Due to financial difficulties, the company implemented a two-stage retrenchment program. Briones did not avail of early retirement and was subsequently retrenched, with her position allegedly taken by Dalisay Arenas, whose retirement application was disapproved. Briones protested her retrenchment, refused separation pay, and filed a complaint for illegal dismissal. Procedural History: The Labor Arbiter ruled in favor of Briones, declaring her retrenchment illegal and ordering reinstatement with backwages. The NLRC affirmed this decision, and the Supreme Court dismissed Marcopper's petition for certiorari (G.R. No. 71740). A writ of execution was issued for reinstatement and payment of backwages. Subsequently, Marcopper filed a motion for recomputation, arguing that Briones' position had been abolished and that she had obtained other employment. The Labor Arbiter, on March 7, 1986, reconsidered the executory decision, ordering separation pay instead of reinstatement and setting a cut-off date for backwages. Both parties appealed to the NLRC. The NLRC vacated the Labor Arbiter's order of March 7, 1986, and ordered the enforcement of the original decision dated October 7, 1983. The Petition: Petitioner Marcopper Mining Corporation filed a petition for certiorari with the Supreme Court, contending that the NLRC committed grave abuse of discretion in reversing the Labor Arbiter's order, arguing that supervening events (abolition of Briones' position) rendered the original decision impossible or unjust to execute.
Issue(s)
Whether a final and executory decision of the NLRC can be modified or altered by the Labor Arbiter before its execution. Whether the abolition of an employee's position constitutes a supervening event that justifies the modification of a final and executory decision ordering reinstatement.
Ruling
The petition is dismissed for lack of merit. The NLRC decision is modified only with respect to the period of backwages, which shall be limited to three (3) years from February 1, 1973, with legal interest until full payment. The case is remanded to the labor arbiter for prompt execution.
Ratio Decidendi
On the issue of modifying a final and executory decision: The Court reiterated the well-settled rule that a judgment which has become final and executory can no longer be amended or corrected by the court except for clerical errors. The Labor Arbiter loses jurisdiction over the case except to execute the final judgment. Any amendment or alteration that substantially affects a final and executory judgment is null and void for lack of jurisdiction. The NLRC correctly held that the Labor Arbiter's order of March 7, 1986, which substantially altered the final and executory decision of October 7, 1983, constituted a reversible error. On the issue of supervening events justifying modification: While acknowledging that final judgments may be modified if facts exist that render execution impossible or unjust, the Court found the facts presented by petitioner Marcopper to be questionable. The Court noted the delay in bringing the alleged abolition of Briones' position to the attention of the Labor Arbiter and the apparent contradiction with Marcopper's earlier petition for certiorari. The Court concluded that the alleged abolition was likely an afterthought to oust respondent Briones, especially considering the earlier finding of illegal dismissal marked with discrimination. The Court emphasized that Briones' right to security of tenure should not be denied due to a scheme to oust her, and that if her position was abolished, she could be reinstated to a substantially equivalent position.
Main Doctrine
A final and executory decision of the NLRC cannot be modified or altered by the Labor Arbiter, except for clerical errors, as the Labor Arbiter loses jurisdiction over the case except to execute the final judgment. Any substantial alteration or modification is null and void for lack of jurisdiction.