Bataan Shipyard and Engineering Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Bataan Shipyard and Engineering Corporation (BASECO) filed an application for retrenchment of 285 employees due to heavy losses incurred since 1979. Executive Labor Arbiter Francisco M. Jose declared the retrenchment legal and valid, ordered BASECO to pay separation pay equivalent to one (1) month or one-half (1/2) month salary for every year of service (whichever is higher), declared BASECO guilty of unfair labor practice for discriminatory selection of retrenched employees, and ordered payment of six (6) months backwages as penalty. Procedural History: BASECO appealed to the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision on December 27, 1985. A Writ of Execution was issued on January 15, 1987, for P4,106,284.00. The Supreme Court dismissed BASECO's petition for certiorari (G.R. No. L-78604) on May 9, 1988, upholding the NLRC decision. Private respondents filed a Motion for Alias Writ of Execution, which was granted on November 29, 1990. BASECO filed a Motion for Reconsideration. The Petition: On July 19, 1991, the NLRC modified the monetary awards to P2,203,563.91 based on a re-computation. Both BASECO and private respondents moved for reconsideration. On October 30, 1991, the NLRC denied both motions. BASECO filed a Petition for Certiorari and Prohibition, seeking to annul the NLRC resolutions and enjoin their implementation. A Temporary Restraining Order was issued on February 17, 1992.
Issue(s)
Whether the NLRC committed grave abuse of discretion in promulgating its Resolutions dated July 19, 1991, and October 30, 1991, by re-computing the monetary awards to conform to the final decision. Whether the claim of payment of separation pay could be raised to further reduce the adjudged economic benefits, despite the finality of the original decision.
Ruling
The petition is DISMISSED for lack of merit. The Temporary Restraining Order issued on February 17, 1992, is LIFTED.
Ratio Decidendi
On the issue of re-computation and reopening of the case: The Supreme Court held that the NLRC did not commit grave abuse of discretion. The re-computation made by the NLRC was to correct errors in the writ of execution which varied the tenor of the final and executory decision of January 30, 1984. The function of a court in executing a decision is purely ministerial and it cannot vary or alter the terms thereof. The NLRC's action was to conform the execution to the original decision, not to reopen the case. The Court reiterated the well-settled rule that an award or judgment becomes final and executory upon the expiration of the period to appeal, and its execution follows as a matter of course. On the issue of alleged payment of separation pay: The Supreme Court found the petitioner's argument to be without merit. The NLRC had repeatedly found that no partial payment had been made to the private respondents. Furthermore, BASECO's own agreement on August 1, 1988, admitting its liability and outlining the computation of awards, contradicted its later defense of payment. The Court emphasized that factual findings of agencies exercising quasi-judicial functions, like the NLRC, are accorded finality. Petitioner failed to submit proof of payment through standard forms like an Affidavit of Satisfaction of Judgment or Quitclaim and Release, thus it could not gratuitously claim a deduction. The claim of payment of separation pay could no longer be advanced by petitioner as it would in effect re-open the decision that had long become final and executory, a matter already laid to rest by the Supreme Court's dismissal of G.R. No. 78604.
Main Doctrine
A claim of payment of separation pay cannot be raised to reopen a decision that has long become final and executory, as the execution of a final judgment is purely ministerial and cannot vary its terms.