Supercars, Inc. v. Minister of Labor and Employment
REITERATIONFacts
The Antecedents: Private respondents, employees of Supercars, Inc., filed a complaint for unfair labor practice. The Regional Director initially ordered Supercars to reinstate the private respondents with full backwages. On appeal, the Minister of Labor and Employment modified this, ordering reinstatement without backwages. Procedural History: Supercars filed a motion for reconsideration, which was denied. Private respondents were reinstated on August 20, 1984. Subsequently, private respondents moved for backwages from September 2, 1983, to August 19, 1984, alleging they were refused entry despite the order for reinstatement. Supercars opposed, arguing the original order did not grant backwages and awarding them would modify a final order. The Regional Director granted the motion and directed payment of backwages. The Minister of Labor and Employment affirmed this. The Petition: Supercars filed a petition for certiorari, arguing that the award of backwages by the Regional Director and affirmed by the Minister of Labor and Employment was an act without or in excess of jurisdiction as it modified a final order that did not include backwages.
Issue(s)
Whether the Regional Director and the Minister of Labor and Employment acted without or in excess of jurisdiction in awarding backwages. Whether the award of backwages constituted a modification of a final and executory order.
Ruling
The petition is granted. The order of the Minister of Labor and Employment dated March 25, 1986, is set aside, and the temporary restraining order issued on April 28, 1986, is made permanent.
Ratio Decidendi
On whether the Regional Director and the Minister of Labor and Employment acted without or in excess of jurisdiction in awarding backwages: The Supreme Court held that the August 1, 1983 order of the Minister of Labor and Employment merely directed reinstatement without backwages. Therefore, the Regional Director acted without or in excess of jurisdiction when he awarded backwages for the period after the ten-day reinstatement period had lapsed until the actual date of reinstatement. The affirmation of this order by the Minister of Labor and Employment was likewise an act without or in excess of jurisdiction. On whether the award of backwages constituted a modification of a final and executory order: The Court emphasized that the award constituted a modification of a final order. It cited hornbook doctrine that a decision which has become final and executory can no longer be amended or corrected by the court except for clerical errors. The Court further noted that the order dated August 1, 1983, had been executed by the reinstatement of private respondents and should not be disturbed. The Court also referenced its ruling in National Steel Corporation vs. National Labor Relations Commission, et al., where it held that a commission acted without or in excess of jurisdiction in awarding backwages when the original decision only ordered reinstatement without backwages. The Court reasoned that the petitioner should not be penalized for the delay in the implementation of the order, especially when the private respondents could have moved for the issuance of a writ of execution. The Court found that the delay was caused by the inaction of the private respondents, and it would be offensive to justice and fair play to hold the petitioner liable for the consequence of such inaction.
Main Doctrine
An award of backwages, when the original order only directed reinstatement without backwages, constitutes a modification of a final and executory order and is therefore an act without or in excess of jurisdiction.