Bearneza v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: This case originated from a complaint filed by petitioner Rommel B. Bearneza against private respondent NFD International Manning Agents, Inc. for permanent total disability benefits. The Philippine Overseas Employment Administration (POEA) initially dismissed the complaint. Procedural History: The National Labor Relations Commission (NLRC) reversed the POEA's decision, granting disability benefits and attorney's fees. The manning agency's motion for reconsideration was denied, and they subsequently filed a petition for certiorari with the Supreme Court (G.R. No. 107131). The Supreme Court issued a temporary restraining order and later dismissed the manning agency's petition. The Court also denied the manning agency's motion for reconsideration and petitioner's motion for damages on the injunction bond. The records were remanded to the NLRC for execution of judgment. An alias writ of execution was issued and satisfied. Petitioner then sought a second alias writ of execution to include 12% annual interest on the judgment award, which was denied by the labor arbiter and affirmed by the NLRC. Petitioner's subsequent petition for certiorari to the Court of Appeals was also dismissed. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court assails the Court of Appeals' decision dismissing petitioner's claim for 12% annual interest on the judgment award. Petitioner argues that the NLRC committed grave abuse of discretion. However, the Court of Appeals ruled that the NLRC did not err, noting that the NLRC's decision had become final and executory, had been executed, and that the issue of interest had already been resolved by the Supreme Court in G.R. No. 107131.
Issue(s)
Whether the petitioner is entitled to the imposition of 12% interest per annum on a judgment award after the judgment has attained finality and has already been fully executed.
Ruling
The petition is denied. The Supreme Court affirmed the decision of the Court of Appeals, holding that the NLRC did not commit grave abuse of discretion. The Court reiterated that a judgment that has become final and executory is immutable and unalterable, and that claims already resolved by the Supreme Court cannot be relitigated.
Ratio Decidendi
On Issue 1: The Court ruled that no abuse of discretion can be imputed to the Labor Arbiter or the National Labor Relations Commission (NLRC) in denying the second alias writ of execution. The NLRC's February 27, 1992 decision, which did not include the 12% interest, became final and executory upon the dismissal of G.R. No. 107131. Furthermore, the Supreme Court explicitly addressed the matter of interest in its resolution dated June 16, 1997, where it denied Bearneza's "motion for damages on the injunction bond" for lack of merit. Applying the principle of 'immutability of judgment' as established in Manotok Realty, Inc. v. CLT Realty Development Corporation, the Court held that a final judgment cannot be modified in any respect, even to correct a perceived error. Since the sheriff's return confirmed that the original judgment award had already been satisfied, the case was effectively closed. Allowing the imposition of interest at this stage would constitute an impermissible modification of a final decree.
Main Doctrine
A judgment that has become final and executory is immutable and unalterable, and claims that have already been resolved by the Supreme Court cannot be relitigated.