Cathay Pacific Airways, Ltd. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: The case involves a dispute between Cathay Pacific Airways, Ltd. (petitioner) and Martha Z. Singson (respondent) concerning the latter's dismissal. Procedural History: The Court of Appeals rendered a decision dated 20 September 1999, declaring the dismissal of respondent Martha Z. Singson by petitioner Cathay Pacific Airways, Ltd. as illegal. The appellate court ordered her reinstatement to her former or an equivalent position without loss of seniority rights, with full back wages and benefits, and awarded her HK$50,000.00 as moral damages and HK$50,000.00 as exemplary damages, plus ten percent (10%) of the total monetary award as attorney's fees. The amounts received by respondent representing her six (6) months retirement gratuity and one (1) month in lieu of notice were to be deducted from respondent's computed back wages. The Petition: The Supreme Court issued a Decision on 2 August 2001. Subsequently, respondent filed a Motion for Correction of Clerical Error dated 17 October 2001.
Issue(s)
Whether there was a clerical error in the dispositive portion of the Supreme Court's Decision dated 2 August 2001. Whether the award of damages and other monetary considerations by the Court of Appeals should be corrected in the Supreme Court's dispositive portion.
Ruling
The Supreme Court RESOLVED to correct, as it hereby corrects, the dispositive portion of its Decision of 2 August 2001 to accurately reflect the awards made by the Court of Appeals. The dispositive portion now reads: WHEREFORE, the Decision of the Court of Appeals dated 20 September 1999 declaring the dismissal of respondent Martha Z. Singson by petitioner CATHAY PACIFIC AIRWAYS, LTD. as illegal and ordering her reinstatement to her former or an equivalent position without loss of seniority rights, with full back wages and benefits, and to pay her HK$50,000.00 as moral damages, HK$50,000.00 as exemplary damages plus ten percent (10%) of the total monetary award as attorney's fees, is AFFIRMED. The amounts received by respondent representing her six (6) months retirement gratuity and one (1) month in lieu of notice should be deducted from respondent's computed back wages, with costs against petitioner.
Ratio Decidendi
On the issue of clerical error: The Court found the respondent's Motion for Correction of Clerical Error to be meritorious. It was established that the Court of Appeals had indeed awarded respondent Martha Z. Singson HK$50,000.00 for moral damages and another HK$50,000.00 for exemplary damages. The Supreme Court's original dispositive portion of its Decision dated 2 August 2001 did not accurately reflect these awarded amounts. The Court acknowledged that such errors, if not corrected, could lead to misinterpretations or incorrect execution of the judgment. The correction was necessary to align the Supreme Court's pronouncement with the actual findings and awards of the appellate court, which the Supreme Court had affirmed. On the correction of the dispositive portion: The Court, finding the motion meritorious, proceeded to correct the dispositive portion of its earlier decision. The corrected dispositive portion explicitly stated the affirmation of the Court of Appeals' decision, including the order for reinstatement, full back wages and benefits, and the specific amounts awarded for moral damages (HK$50,000.00) and exemplary damages (HK$50,000.00). It also reiterated the award of attorney's fees and the directive for deduction of retirement gratuity and notice pay from the back wages. This action ensures that the final judgment accurately represents the monetary awards and other reliefs granted to the respondent, thereby preventing any ambiguity in its enforcement.
Main Doctrine
The Supreme Court granted a motion for correction of clerical error in its dispositive portion to accurately reflect the awarded damages and other monetary considerations, affirming the Court of Appeals' decision.