Morales v. Hubilla
REITERATIONFacts
1. The Antecedents: Respondent Joselito Hubilla was hired as a Technical Salesman by petitioner Marmosy Trading, Inc., a domestic corporation distributing chemicals, with petitioner Victor Morales serving as its President and General Manager. Marmosy Trading, Inc. terminated Hubilla's employment effective July 15, 1997. In response, Hubilla filed a complaint for illegal dismissal, illegal deduction, and diminution of benefits against Marmosy Trading, Inc. and Victor Morales before the Labor Arbiter. 2. Procedural History: Labor Arbiter Daniel C. Cueto rendered a decision on May 31, 1999, finding Hubilla's termination illegal and ordering his reinstatement with full backwages and attorney's fees. This decision was affirmed by the National Labor Relations Commission (NLRC) on May 31, 2000, and became final and executory on June 26, 2000. Petitioners' subsequent petition to the Court of Appeals (CA G.R. SP No. 60226) was dismissed for procedural infirmities, and this dismissal was affirmed by the Supreme Court in G.R. No. 145881. Despite multiple attempts by petitioners to delay execution through various motions and appeals, including challenges to computation and the levy on execution of Victor Morales' real property, the NLRC and the Court of Appeals consistently upheld the execution of the original judgment. 3. The Petition: This petition for review under Rule 45 of the Rules of Court assails the Decision of the Court of Appeals dated July 14, 2005, and its Resolution dated November 16, 2005, which affirmed the NLRC's Resolution of January 30, 2004. The core issue presented is whether the Court of Appeals erred in allowing the levy on execution on the real property of petitioner Victor Morales. Petitioners argue that Morales, as president, should not be held personally liable for corporate debts and that his property should not be subject to execution. The Supreme Court noted that the petitioners had exhausted all available remedies and that the judgment had long become final and executory, rendering further challenges to execution impermissible.
Issue(s)
Whether the Court of Appeals erred in allowing the notice of levy to be annotated on the title of the real property registered under the name of petitioner Victor Morales. Whether the decision dated July 14, 2005, and the resolution dated November 16, 2005, of the Court of Appeals in CA G.R. SP No. 85989 are in accordance with law and existing jurisprudence.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals in CA G.R. SP No. 85989 dated July 14, 2005, and its Resolution dated November 16, 2005, are affirmed.
Ratio Decidendi
On the issue of allowing the levy on execution on Victor Morales' real property: The Supreme Court held that the decision of the Labor Arbiter, rendered on May 31, 1999, had long become final and executory. This judgment was affirmed by the NLRC, the Court of Appeals, and ultimately by the Supreme Court itself in G.R. No. 145881. The Court emphasized the principle of immutability of judgments, stating that once a judgment becomes final and executory, it can no longer be modified in any respect, except for clerical errors or void judgments. The series of pleadings and appeals filed by the petitioners were deemed as attempts to delay the execution of the final and executory decision, which the Court disfavors. The Court reiterated that a prevailing party should not be denied the fruits of his victory by any subterfuge devised by the losing party. The writ of execution issued by the Labor Arbiter was consistent with the final decision, and therefore, it was beyond challenge. Petitioner Victor Morales, as president of the corporation, could not escape liability for the corporation's obligations, especially when the company had ceased operations, and the judgment had become final and executory. The Court noted that it is no longer legally feasible to modify the final ruling through a petition questioning the order of execution, and petitioner Victor Morales was barred by the final judgment from advancing arguments against the liability of his real property for the monetary award. On whether the CA decisions are in accordance with law and jurisprudence: The Supreme Court found that the CA decisions were indeed in accordance with law and jurisprudence. The Court highlighted that petitioners had exhausted all available remedies, with their petition in G.R. No. 145881 being denied by the Supreme Court. The execution of the judgment ought to have taken place as a matter of right after the finality of G.R. No. 145881. The subsequent delays were attributed to the petitioners' persistent filing of pleadings, motions, and appeals. The Court stressed that trial and execution proceedings constitute one whole action, and a case with an issued execution is considered still pending. The final judgment in this case could no longer be reviewed or modified, directly or indirectly, by any court, including the Supreme Court, as litigation must end, and the winning party must not be deprived of the fruits of the verdict. The Court must guard against schemes to prolong controversies and frown upon attempts to do so.
Main Doctrine
Once a judgment becomes final and executory, it becomes immutable and unalterable, and the prevailing party should not be denied the fruits of his victory by any subterfuge. The enforcement of a final and executory judgment cannot be unduly delayed by a series of pleadings and appeals filed by the losing party.