Veterans Philippine Scout Security Agency v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Roberto De los Santos was employed as a security guard by Veterans Philippine Scout Security Agency on March 16, 1982, assigned to Prudential Bank's Naga City branch. On February 6, 1985, he was relieved due to complaints from the bank manager and ordered to report to the agency's Quezon City office for an inquiry. De los Santos reported on May 21, 1985, citing financial problems, and requested reassignment to Naga City or Metropolitan Manila. The agency aborted the inquiry, accepted his explanation, and instructed him to wait for a new assignment, providing a P500.00 monthly allowance with free board and lodging. Procedural History: Feeling ridiculed and oppressed, De los Santos filed a Complaint for illegal dismissal and money claims against the agency and its officials, Willie O. Jamila and Sergio Jamila, with the National Labor Relations Commission (NLRC) on May 23, 1985. After hearings and submission of position papers, the labor arbiter rendered a Decision on February 27, 1986, ruling in favor of De los Santos, ordering reinstatement without loss of seniority rights, and payment of backwages, emergency cost of living allowance, 13th month pay, holiday pay, incentive leave pay, moral and exemplary damages, litigation fees, and attorney's fees. The Petition: The Veterans Philippine Scout Security Agency filed a petition questioning the final and executory character of the labor arbiter's decision. Roberto De los Santos also filed a separate petition.
Issue(s)
Whether the Decision of the labor arbiter is final and executory. Whether the dismissal of Roberto De los Santos was illegal.
Ruling
The Court ruled that the Decision of the labor arbiter is final and executory. The petitions were dismissed.
Ratio Decidendi
On the final and executory character of the labor arbiter's Decision: The Court held that the Decision of the labor arbiter dated February 27, 1986, had become final and executory. The records show that the respondents were furnished a copy of the Decision on March 17, 1986. Under the Labor Code, decisions of labor arbiters become final and executory after ten (10) calendar days from receipt thereof, unless a temporary restraining order or injunction has been issued by the Supreme Court. In this case, no such restraining order or injunction was issued. Therefore, the Decision became final and executory on March 27, 1986. The petitions filed by the Veterans Philippine Scout Security Agency and Roberto De los Santos were filed long after the Decision had become final and executory. The Court reiterated that a judgment that has become final and executory can no longer be modified or amended, except for clerical errors. The agency's contention that the decision was not yet final was without merit as it failed to present any evidence of a restraining order or appeal within the reglementary period. The petitions were thus filed out of time and were correctly dismissed by the NLRC on that ground. On whether the dismissal of Roberto De los Santos was illegal: There is no ratio provided in the text regarding the legality of Roberto De los Santos' dismissal. The provided text focuses solely on the finality and executory nature of the labor arbiter's decision.
Main Doctrine
A Decision of a labor arbiter, once final and executory, becomes the law of the case and can no longer be modified or amended except for clerical errors.