Manning International Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Francisco Benedicto was hired by Abdulasis & Mohamed A. Aljomaih Co., through its Philippine representative Manning International Corporation, as a truck driver in Saudi Arabia for a two-year term. While employed, Benedicto was involved in a vehicular accident, resulting in the loss of both his legs. He was hospitalized from February 2, 1982, until May 1982, when his employment was terminated. He was repatriated to the Philippines in August 1982. Procedural History: In October 1982, Benedicto filed a complaint with the Philippine Overseas Employment Administration (POEA) for salary for the unexpired portion of his contract, insurance benefits, and medical expenses. The respondents failed to appear or present evidence despite due notice. The POEA, in a decision dated March 19, 1984, dismissed Benedicto's claim for salary but ordered the employers to pay P12,000.00 as total and permanent disability benefit and actual medical expenses subject to verification. The employers' motion for reconsideration and new trial was denied by the National Labor Relations Commission (NLRC) in a Resolution dated September 28, 1984. Benedicto moved for computation of amounts due, submitting receipts for medical expenses from September 3, 1982, to January 26, 1985. The POEA Administrator, in an Order dated July 8, 1986, overruled the employers' objection and directed the issuance of an alias writ of execution for P12,000.00 disability benefits and P19,450.00 for 120 days of medical expenses. Benedicto moved for partial reconsideration regarding the limitation of medical expenses to 120 days. The NLRC, in a Decision dated April 15, 1988, set aside the POEA Order and awarded Benedicto P65,621.03 as reimbursement for actual medical expenses from September 3, 1982, to January 26, 1985, citing equity and social justice. The Petition: The employers filed a petition for certiorari with the Supreme Court, assailing the NLRC's Decision dated April 15, 1988, contending that Benedicto was estopped from further claims and that the decision was without legal basis and unjust.
Issue(s)
Whether the NLRC could alter a final and executory judgment based on equity and social justice. Whether Benedicto was estopped from claiming further medical expenses. Whether the NLRC's decision awarding P65,621.03 for medical expenses was legally tenable.
Ruling
The Supreme Court granted the petition, annulling and setting aside the NLRC's Decision dated April 15, 1988, and reinstating and affirming the POEA Order dated July 8, 1986. The Court ruled that a final and executory judgment is immutable and cannot be modified, even on grounds of equity and social justice, unless it falls under recognized exceptions like clerical errors or void judgments.
Ratio Decidendi
On the immutability of final and executory judgments and the application of equity and social justice: The Court held that the NLRC's "new judgment" of April 15, 1988, which altered the POEA's final and executory judgment of March 19, 1984, was void ab initio. The principle of immutability of judgment dictates that once a judgment becomes final and executory, it can no longer be modified in any respect, even to correct perceived errors of fact or law. The only exceptions are clerical errors or nunc pro tunc entries that do not prejudice any party, or if the judgment itself is void. The NLRC's alteration was not a clerical correction but a substantial modification of the rights and obligations determined in the original judgment. The Court cited Lichauco vs. Tan Pho to emphasize that nunc pro tunc judgments are for placing in proper form what was previously rendered, not for correcting judicial errors or supplying non-action. The Court found that the NLRC's decision to award a significantly higher amount for medical expenses was based on "considerations of equity and social justice" and the theory that medical treatment should continue until the injury is healed. However, the Court reiterated that equity cannot prevail against an express provision of law. In this case, the NLRC's reliance on equity was impermissible as it directly contradicted the established final and executory judgment of the POEA. The Court cited its own ruling in a similar case where equitable considerations could not override the Labor Code provisions disallowing separation pay for dismissals due to cause. On estoppel regarding further medical expenses: The provided text does not contain explicit reasoning on whether Benedicto was estopped from claiming further medical expenses. Therefore, no ratio is provided for this issue. On the employers' liability for medical expenses: The POEA's final and executory judgment had already determined the employers' liability for P12,000.00 in disability benefits and P19,450.00 for 120 days of medical expenses. The NLRC's subsequent decision to award P65,621.03 for medical expenses covering a much longer period was a clear modification of this executory judgment. The Court noted that the employers had already defrayed substantial medical expenses in Saudi Arabia and that Benedicto had received compensation from those responsible for the accident. The NLRC's attempt to increase the award based on equity disregarded the finality of the prior ruling and the existing factual circumstances.
Main Doctrine
A final and executory judgment is immutable and unalterable, and cannot be modified even by the highest court, except for clerical errors or nunc pro tunc entries, or if the judgment is void. The NLRC cannot alter a final and executory judgment based on equity and social justice.