Industrial Management International Development Corp. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents filed a complaint against Filipinas Carbon Mining Corporation, Gerardo Sicat, Antonio Gonzales, Chiu Chin Gin, Lo Kuan Chin, and petitioner Industrial Management International Development Corp. (INIMACO) for separation pay and unpaid wages. Procedural History: The Labor Arbiter rendered a Decision dated March 10, 1987, ordering the respondents to pay specific amounts to individual complainants, totaling P138,588.31. No appeal was filed, and the decision became final and executory. An Alias Writ of Execution was issued, ordering the collection of the aggregate award from respondents Antonio Gonzales/INIMACO and/or Filipinas Carbon and Mining Corporation and Gerardo Sicat. Petitioner INIMACO filed a motion to quash the alias writ, alleging it altered the judgment by making their liability solidary instead of joint. The Labor Arbiter denied the motion. The National Labor Relations Commission (NLRC) dismissed INIMACO's appeal, holding that the writ of execution was proper and that the Commission could waive errors to give full meaning to labor justice. INIMACO then filed a motion to compel the sheriff to accept its pro rata share, which was also denied. The NLRC affirmed the denial, stating that the writ clarified an ambiguity in the dispositive portion. The Petition: Petitioner INIMACO filed a petition for certiorari with the Supreme Court, assailing the NLRC's Resolution dated September 4, 1991, for grave abuse of discretion in upholding the Alias Writ of Execution which allegedly made INIMACO's liability solidary despite the absence of such declaration in the final judgment.
Issue(s)
Whether petitioner's liability pursuant to the Decision of the Labor Arbiter dated March 10, 1987, is solidary or joint.
Ruling
The petition is GRANTED. The Resolution dated September 4, 1991, of the respondent National Labor Relations Commission is declared NULL and VOID. The liability of the respondents in RAB-VII-0711-84 pursuant to the Decision of the Labor Arbiter dated March 10, 1987, is considered joint and petitioner's payment is considered full satisfaction of its liability, without prejudice to the enforcement of the award against the other five (5) respondents.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petitioner's liability is joint, not solidary. Citing Article 1207 of the Civil Code, the Court reiterated that solidary liability cannot be lightly inferred and exists only when expressly stated by the obligation, the law, or the nature of the obligation. The dispositive portion of the Labor Arbiter's decision did not use the term 'solidary' or 'joint and several,' thus the presumption of joint liability applies. Furthermore, applying the doctrine in Oriental Commercial Co. v. Abeto, the Court noted that even if a prior contract stipulated solidary liability, the final judgment supersedes that contract; if the judgment itself is silent on solidarity, it cannot be executed as such. The Court emphasized that once a judgment becomes final and executory, it becomes immutable and unalterable. Consequently, the Labor Arbiter and the NLRC lacked jurisdiction to change the nature of the liability during the execution phase, as an order of execution that varies the tenor of the judgment is a nullity.
Main Doctrine
An alias writ of execution that varies the tenor of a final and executory judgment is a nullity for lack of jurisdiction. Solidary liability cannot be inferred and must be expressly stated in the dispositive portion of the judgment.