Blanco v. Philippine Automotive Mfg.
REITERATIONFacts
The Antecedents: Nestor V. Blanco filed a complaint for illegal dismissal against Philippine Automotive Manufacturing Corporation (PAMCOR). The Labor Arbiter ruled in favor of Blanco, ordering PAMCOR to reinstate him and pay full backwages of ₱24,398.40 and attorney's fees. Procedural History: The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision but deleted the attorney's fees. This decision became final and executory. PAMCOR paid the backwages and reinstated Blanco as a probationary machinist. Despite this, Blanco filed a motion for recomputation of backwages and for reinstatement as a regular employee. The Labor Arbiter granted both motions, ordering PAMCOR to pay additional backwages and reinstate Blanco as a regular machinist. PAMCOR appealed to the NLRC, which reversed the Labor Arbiter's order. Blanco's subsequent petition for certiorari with the Court of Appeals was dismissed. The Court of Appeals also denied the motions for reconsideration. The Petition: Both Blanco and PAMCOR filed petitions for review on certiorari with the Supreme Court, assailing the Court of Appeals' decision.
Issue(s)
Whether the Court of Appeals erred in not considering Blanco's employment status as regular and in denying Blanco's claim for additional backwages of ₱99,995.04. Whether the Court of Appeals erred in nullifying the NLRC's second assailed Decision.
Ruling
The Supreme Court denied both petitions, affirming the assailed Decision and Resolution of the Court of Appeals. The Court held that the NLRC Decision dated July 18, 1996, which had become final and executory, could no longer be modified by the Labor Arbiter. The subsequent order of the Labor Arbiter directing additional backwages and reinstatement as a regular employee was an overstepping of jurisdiction.
Ratio Decidendi
On the issue of employment status and additional backwages: The Court reiterated the principle that a judgment that has attained finality is immutable and beyond modification. The NLRC Decision dated July 18, 1996, which ordered reinstatement and payment of ₱24,398.40 in backwages, had become final and executory. This definitive judgment could not be changed, revised, amended, or reversed. The subsequent actions of the Labor Arbiter in ordering additional backwages and reinstatement as a regular employee constituted a modification of an already immutable decision. The Court emphasized that once a judgment becomes final, nothing can be done except its execution; otherwise, litigations would have no end. The Labor Arbiter, by issuing an order that modified the final and executory NLRC decision, clearly overstepped his jurisdiction. The Court of Appeals correctly dismissed Blanco's petition on this ground, as the Labor Arbiter acted without jurisdiction in modifying a final and executory judgment. The Court cited King Integrated Security Services, Inc. vs. Gatan to underscore the finality of judgments. On the issue of the Court of Appeals' nullification of the NLRC's second assailed Decision: The Court found that the Court of Appeals correctly nullified the NLRC's second assailed Decision because the Labor Arbiter, in issuing the June 23, 1998 Order, had already acted without jurisdiction by modifying a final and executory judgment. Therefore, any subsequent proceedings or decisions based on that erroneous order would also be tainted with lack of jurisdiction. The Court of Appeals' finding that the Labor Arbiter's order was void for lack of jurisdiction was thus upheld. The Court affirmed the appellate court's dismissal of Blanco's petition, as the issues raised by Blanco regarding his employment status and additional backwages were predicated on the Labor Arbiter's order that was void for having been issued with grave abuse of discretion amounting to lack of jurisdiction.
Main Doctrine
A judgment that has become final and executory is beyond the power of any court, including the Supreme Court, to modify or alter, except for its execution. Any attempt by a lower court or tribunal to modify such a judgment constitutes an overstepping of jurisdiction.