Aboitiz Shipping Employees Association v. Trajano
REITERATIONFacts
The Antecedents: Petitioner Aboitiz Shipping Employees Association (ASEA) filed a complaint against Aboitiz Shipping Corporation (ASC) for non-compliance with mandated minimum wages under Presidential Decrees (P.D.) Nos. 1713 and 1751, and Wage Orders 1 through 6. The complaint alleged underpayment of daily allowances. The National Capital Region Regional Office of the Department of Labor and Employment (DOLE) conducted an inspection and, after evaluating the evidence, ordered ASC to pay P1,350,828.00 for underpayment of daily allowances from February 16, 1982, to February 15, 1985, and to continue paying the deficiency thereafter. Procedural History: ASC appealed the Regional Director's order to the Secretary of Labor, who dismissed the appeal. ASC's motion for reconsideration was also denied. On petition for certiorari, the Supreme Court affirmed the order with a modification, excluding one complainant due to a compromise agreement. ASC's subsequent motion for reconsideration was denied. ASEA then filed a motion for an alias writ of execution, which the Regional Director granted. However, on ASC's appeal, the Secretary of Labor set aside the execution order and created a Special Committee to recompute ASC's liability. The Committee, reviewing new evidence from ASC, reduced the award to P209,183.42, which the Secretary of Labor approved. ASEA's motion for reconsideration of this reduction was denied. The Petition: ASEA filed a petition for certiorari, arguing that the Undersecretary of Labor and Employment committed grave abuse of discretion in modifying the Regional Director's award, which had become final and executory. ASEA contended that the Regional Director's award of P1,350,828.00 was already settled by a previous Supreme Court decision and that the Secretary of Labor lacked jurisdiction to reduce it based on evidence that ASC failed to present during the original proceedings. ASEA sought the reinstatement of the original award and the execution thereof.
Issue(s)
Whether the public respondent committed grave abuse of discretion in modifying a final and executory decision of the Regional Director. Whether the Regional Director's award of P1,350,828.00, which had become final and executory, could be reduced by the Secretary of Labor based on newly adduced evidence.
Ruling
The petition is impressed with merit. The assailed orders of the public respondent Undersecretary are set aside, and the resolution of the Regional Director ordering the issuance of an alias writ of execution is reinstated.
Ratio Decidendi
On the issue of modifying a final and executory decision: The Court reiterated the settled rule that after a judgment has become final and executory, it can neither be amended nor altered, even if the purpose is to correct a perceived conclusion of fact or law. This principle holds true regardless of whether the modification is made by the magistrate who rendered the judgment or by an appellate magistrate. The Court emphasized that all litigation must come to an end, and allowing modifications to final judgments would make litigation more intolerable than the wrong it seeks to correct. The Court acknowledged an exception where circumstances transpire after the judgment has become final and executory, rendering its execution unjust and inequitable, but stressed that this exception does not apply when the basis for modification is the same evidence that was available but not presented during the merits hearing. On the reduction of the award: The public respondent justified the reduction based on the Special Committee's findings that ASC had complied with various wage laws and orders, except for minimal adjustments. However, the Court found this justification unacceptable because ASC's liability had already been settled by this Court in a prior decision, Aboitiz Shipping Corporation v. Hon. Dionisio de la Serna, et. al., which affirmed the Regional Director's award of P1,350,828.00. Therefore, as correctly held by the Regional Director, the judgment was final and executory, and the amount adjudged should be the subject of execution, not re-evaluation based on evidence that should have been presented earlier.
Main Doctrine
A final and executory judgment can neither be amended nor altered, even if the purpose is to correct a perceived conclusion of fact or law, unless the modification is based on circumstances that transpired after the judgment became final and executory.