Times Transit Credit Coop., Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Margarita Cariño was employed as a clerk by petitioner Times Transit Credit Cooperative, Inc. (TTCCI) from July 10, 1985, until her termination on June 16, 1990. Her dismissal was based on serious misconduct for allegedly acting without authority from petitioner when she delivered papers intended for petitioner to its governing board on June 13, 1990, after being interviewed by a labor inspector on June 5, 1990. Procedural History: Private respondent filed a complaint for illegal dismissal, underpayment of wages, non-payment of wages, and thirteenth month pay. The Labor Arbiter declared the dismissal illegal, ordered TTCCI to pay backwages, separation pay, and 13th month pay differential, while dismissing claims for underpayment and moral damages. The NLRC affirmed this decision. TTCCI's motion for reconsideration, arguing for the deduction of earnings from subsequent employment at UNP Cooperative, was denied for failure to present evidence of such earnings. A subsequent motion for clarification and recomputation was also denied as it was considered a second motion for reconsideration. An entry of judgment was issued. During the pre-execution conference, TTCCI again moved to have private respondent declare her income from UNP Cooperative for deduction. This was denied by the Executive Labor Arbiter, who stated she lacked the power to alter the NLRC decision. The NLRC affirmed this order, emphasizing that the decision had become final and executory. TTCCI's motion for reconsideration of this affirmation was also denied, leading to the present petition for certiorari. The Petition: Petitioner seeks to set aside the NLRC's decision and resolution, arguing that the NLRC committed grave abuse of discretion in affirming the denial of its motion to deduct private respondent's earnings elsewhere from the backwages awarded. Petitioner contends that the computation and presentation of proof of income earned elsewhere should be ventilated in the execution proceedings.
Issue(s)
Whether the NLRC committed grave abuse of discretion in affirming the labor arbiter's order on the ground that the judgment in the main case had become final and executory. Whether the income earned by private respondent from another employment during the pendency of the illegal dismissal case should be deducted from the backwages awarded.
Ruling
The petition is denied, and the assailed decision of the NLRC is affirmed. Double costs against petitioner.
Ratio Decidendi
On the issue of whether the NLRC committed grave abuse of discretion in affirming the order on the ground that the judgment was final and executory: The Court ruled that the NLRC did not commit grave abuse of discretion. The decision in the illegal dismissal case had become final and executory. Petitioner's subsequent attempts to have private respondent's earnings elsewhere deducted from the monetary awards were essentially stratagems to modify a final judgment. It is a fundamental principle that a final and executory decision cannot be amended or corrected except for clerical errors. Once a judgment becomes final and executory, the court loses jurisdiction over it, except to order its execution. Allowing such modifications would make a farce of duly promulgated decisions that have attained finality. Litigation must be terminated at some point, and the prevailing party should not be denied the fruits of their victory by subterfuge. On the issue of whether private respondent's earnings elsewhere should be deducted from the backwages awarded: The Court affirmed the ruling that such deductions are generally not allowed, citing the case of Bustamante vs. NLRC. Conformably with the legislative intent of Rep. Act No. 6715, backwages awarded to an illegally dismissed employee should not, as a general rule, be diminished by earnings derived elsewhere during the period of illegal dismissal. The rationale is that the employee needs to earn a living while litigating, while the employer must pay full backwages as a penalty for illegally dismissing the employee. Furthermore, the petitioner failed to establish the amount private respondent earned elsewhere by presenting payrolls or other evidence. Even if such earnings were proven, the final and executory nature of the judgment precluded modification to allow for such deductions.
Main Doctrine
A final and executory judgment can no longer be altered or modified, even if the modification is intended to correct an erroneous conclusion of fact or law. The NLRC did not commit grave abuse of discretion in denying the petitioner's motion to deduct earnings from other employment from the backwages awarded, as the main decision had already become final and executory.