Griffith v. Estur
REITERATIONFacts
The Antecedents: Respondents Angelito Estur, Juan Ofalsa, and Rolando Ereve filed an amended complaint against Lincoln Gerald, Inc. and petitioner Dominic Griffith for illegal dismissal, nonpayment of legal holiday pay, 13th month pay, and service incentive leave pay. Lincoln Gerald, Inc., a furniture manufacturing company owned by the Griffith family, had petitioner Dominic Griffith as its Vice President for Southeast Asia Operations. Labor Arbiter Vicente R. Layawen ruled in favor of the respondents, declaring the dismissal of Juan Ofalsa and Rolando Ereve illegal and ordering payment of backwages and separation pay, while partially awarding 13th month pay to Angelito Estur. Procedural History: Lincoln filed a notice of appeal but failed to submit the required memorandum, leading to the finality and executory nature of Labor Arbiter Layawen's decision on July 6, 2001. A writ of execution was issued, and subsequently, an alias writ of execution was directed against both Lincoln and petitioner Dominic Griffith. Petitioner filed a motion to quash this alias writ, arguing he was unaware of the case and that the inclusion of an execution fee modified the original decision. Labor Arbiter Jaime Reyno denied this motion, and the National Labor Relations Commission (NLRC) denied petitioner's subsequent motion for reconsideration. Petitioner then filed a petition for certiorari with the Court of Appeals, which was dismissed, leading to the present petition for review. The Petition: Petitioner Dominic Griffith seeks review of the Court of Appeals' decision, arguing that the NLRC committed grave abuse of discretion. The core of the petition challenges the validity of the first alias writ of execution, specifically its inclusion of an execution fee and the personal liability imposed on him as a corporate officer. Petitioner contends that the writ modified the final and executory decision of Labor Arbiter Layawen. The petition is filed under Rule 45 of the 1997 Rules of Civil Procedure, seeking to overturn the appellate court's affirmation of the NLRC's denial of his motion to quash the writ.
Issue(s)
Whether the Court of Appeals erred in ruling that the NLRC did not commit grave abuse of discretion in upholding the order of Labor Arbiter Reyno, denying the motion to quash the writ of execution, and whether the inclusion of an execution fee in the writ of execution constitutes a modification of the final and executory decision of the Labor Arbiter. Whether petitioner, as a corporate officer, is personally liable for the judgment debt. On the procedural aspect of the motion to quash.
Ruling
The petition is without merit. The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals.
Ratio Decidendi
On the validity of the writ of execution and the inclusion of the execution fee: The Supreme Court reiterated that a decision that has attained finality becomes immutable and unalterable. Petitioner could no longer challenge the Labor Arbiter's decision, which had become final and executory. While a party can question the manner of execution if it deviates from the judgment's tenor, the inclusion of an execution fee does not constitute a modification of the decision. The Court cited Section 6, Rule IX of the Sheriff Manual, which mandates the collection of execution fees from the losing party and holds sheriffs administratively liable for failure to do so. Therefore, the writ was in accordance with the law and rules governing execution. On petitioner's personal liability as a corporate officer: The Court emphasized that the writ of execution was in accord with the terms of Labor Arbiter Layawen's decision, which found Lincoln and petitioner solidarily liable. Since the decision was already final and executory, petitioner was bound by it and could not impugn it. The Court cited the doctrine of finality of judgment, stating that once a judgment attains finality, it becomes immutable and unalterable, even if the modification is meant to correct an erroneous conclusion of fact or law. The petitioner's argument that he was merely a corporate officer acting in good faith and within his authority was irrelevant as the final decision held him solidarily liable. On the procedural aspect of the motion to quash: The Court of Appeals correctly held that the NLRC did not commit grave abuse of discretion. The appellate court noted that Section 19, Rule V of the NLRC Rules prohibits motions for reconsideration of a Labor Arbiter's order or decision, but if filed, it should be treated as an appeal. Petitioner's motion to recall the writ of execution could not be treated as an appeal. Furthermore, the Court of Appeals found no evidence to substantiate petitioner's claim that he was no longer connected with Lincoln by 17 September 1997, indicating no change in the situation of the parties that would exempt him from liability.
Main Doctrine
A writ of execution must be enforced in accordance with the terms and conditions of the final and executory decision it seeks to implement. Any deviation therefrom can be the subject of a proper appeal. The inclusion of execution fees, as provided by rules and regulations, does not constitute a modification of the original decision.