Industrial Timber Corp. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: In a prior case (G.R. No. 83616), the Supreme Court affirmed the National Labor Relations Commission's (NLRC) finding that petitioners were the employers of private respondents and remanded the case for determination of the validity of a quitclaim. The NLRC, in a resolution dated February 3, 1992, affirmed the Labor Arbiter's decision ordering petitioners to reinstate private respondents without loss of seniority, and to pay back wages, ECOLA, 13th month pay, holiday pay, vacation and sick leave pay (P24,300 each), moral and exemplary damages (P10,000 each), and attorney's fees. Due to the lapse of time, severance benefits were also ordered if reinstatement was no longer possible. Procedural History: The NLRC resolution became final and executory on March 9, 1992. Private respondents filed an ex parte motion for execution on March 20, 1992, asserting they had not been reinstated and were entitled to back salaries from February 26, 1987, until actual reinstatement. The Executive Labor Arbiter directed a computation, which resulted in P175,964.84 per private respondent, representing three years of back wages, ECOLA, 13th month pay, holiday pay, leave pay, damages, and attorney's fees, totaling P387,122.65. Both parties objected to this computation. The case was transferred to Labor Arbiter Leon P. Murillo, who concurred with the computation. The NLRC, on appeal, slightly modified the award to P375,795.20. Petitioners' motion for reconsideration, filed via JRS-Butuan, was denied for tardiness as it was received a day late. The Petition: Petitioners faulted the NLRC with grave abuse of discretion for modifying the award and denying their motion for reconsideration.
Issue(s)
Whether the NLRC committed grave abuse of discretion in modifying the monetary award despite the finality of its previous decision. Whether the NLRC erred in denying the motion for reconsideration on the ground of tardiness.
Ruling
The petition is DISMISSED. The resolutions of the NLRC dated May 31, 1993, and August 31, 1993, are AFFIRMED.
Ratio Decidendi
On the modification of the award: The Court disagreed with the petitioners' contention that the NLRC decision of February 3, 1992, which affirmed the Labor Arbiter's order, could not be recomputed. While it is true that a final and executory judgment cannot be modified, this principle admits of exceptions. Such exceptions exist where facts and circumstances transpire that render the execution of the judgment impossible or unjust, necessitating modification in the interest of justice to harmonize the disposition with prevailing circumstances. The Court cited Seavan Carrier Inc. vs. GTI Sportswear Corp. and Pascual vs. Tan to support this exception. In this case, the recomputation was necessary because five years had elapsed from the Labor Arbiter's decision in 1987 to the recomputation in 1992. The original award of P24,300.00 per private respondent only covered the period from their dismissal in April 1986 to February 1987. Since they were not reinstated and the monetary awards were not paid, a recomputation was essential to arrive at a just and proper determination of the monetary awards due, reflecting the actual period of non-reinstatement and non-payment. The Court also noted that a similar action was taken in Sampaguita Garments Corporation v. NLRC. On the tardiness of the motion for reconsideration: The Court found that the NLRC correctly applied the rule that pleadings filed by ordinary mail or private messengerial service are deemed filed on the date of actual receipt by the court, not the date of mailing. The petitioners' counsel claimed delivery to JRS-Butuan on June 26, 1993, a Saturday, which would have made the following Monday, June 28, 1993, the last day to file. However, the motion for reconsideration reached the Commission on June 29, 1993, a day late. The Court reiterated the established rule from Benguet Electric Cooperative, Inc. v. NLRC that the date of delivery to a private carrier is not the date of filing. Moreover, the NLRC noted that the motion contained no substantial matters warranting reconsideration, thus it could have been denied on that ground as well.
Main Doctrine
A final and executory judgment may be modified in the interest of justice to harmonize the disposition with prevailing circumstances, especially when supervening events render its execution impossible or unjust. Furthermore, pleadings filed through private messengerial services are deemed filed on the date of actual receipt by the court, not the date of mailing.