King Integrated Security Services, Inc. v. Gatan
REITERATIONFacts
The Antecedents: Respondent Galo S. Gatan filed a complaint against petitioners King Integrated Security Services, Inc. and/or Mina King for illegal deduction and underpayment of wages. Procedural History: The Labor Arbiter ordered petitioners to pay respondent P184,780.30 as wage differential. On appeal, the National Labor Relations Commission (NLRC) modified the decision by deleting the wage differential for the period from November 2, 1990, to February 10, 1992, citing Article 291 of the Labor Code regarding the prescriptive period for money claims. The NLRC Resolution became final and executory. Petitioners' appeal to the NLRC from the order of execution was dismissed, as was their motion for reconsideration. Subsequently, the Court of Appeals dismissed petitioners' petition for certiorari, affirming the NLRC resolutions with a modification regarding the monetary award for a specific period. Petitioners' motion for partial reconsideration was denied. The Petition: Petitioners assail the Court of Appeals' decision and resolution, alleging that the appellate court erred in disregarding their documentary evidence showing full salary payment and in failing to consider respondent's admission regarding his salary rates on specific dates.
Issue(s)
Whether the Court of Appeals erred in disregarding petitioners' documentary evidence showing that respondent received his salary in full, and whether it erred in failing to consider respondent's admission regarding his monthly salary rates on specific dates. Whether an order of execution of a final and executory judgment is appealable.
Ruling
The petition lacks merit. The Supreme Court denied the petition and set aside the assailed Decision and Resolution of the Court of Appeals.
Ratio Decidendi
On the alleged errors of the Court of Appeals regarding evidence: While the Court of Appeals gave due course to the petition for certiorari, the Supreme Court found that the petition lacked merit. The core issue was the appealability of the order of execution. The Supreme Court's primary finding was that the Court of Appeals should not have entertained the appeal from the order of execution in the first place. Consequently, the alleged errors in disregarding documentary evidence and failing to consider admissions became secondary to the procedural defect of appealing an unappealable order. The Supreme Court's decision to set aside the Court of Appeals' ruling was based on the fundamental principle that a final and executory judgment must be executed without further delay or challenge through appeal. On the appealability of an order of execution: The Supreme Court reiterated the settled rule that an order of execution of a final and executory judgment is not appealable. The Court emphasized that once a judgment becomes final and executory, it is the ministerial duty of the court or tribunal to order its execution. Allowing appeals from such orders would lead to endless litigations, defeating the purpose of courts to resolve controversies with finality. The Court cited its ruling in Fabular vs. Court of Appeals to underscore that after a judgment has become final, nothing can be done except its execution. Therefore, the Court of Appeals clearly overstepped its jurisdiction when it gave due course to the petition for certiorari and evaluated the parties' evidence, despite the fact that what was being assailed was an NLRC Resolution ordering the issuance of a writ of execution.
Main Doctrine
An order of execution of a final and executory judgment is not appealable, as it is the ministerial duty of the court or tribunal to order its execution once a decision or resolution becomes final and executory. Otherwise, there would be no end to litigations.