Manning International Corporation vs. NLRC

A final and executory judgment is immutable and unalterable, and cannot be modified even on grounds of equity and social justice.

Francisco "Lazaro" S. Benedicto was hired by Abdulasis & Mohamed A. Aljomaih Co., through its Philippine representative Manning International Corporation, as a truck driver in Riyadh, Saudi Arabia, for a two-year term. His employment contract provided for workmen's compensation benefits for service-connected injuries in accordance with the social insurance laws of Saudi Arabia and other pertinent laws. When he was injured and lost both legs, the POEA applied Philippine law to determine his benefits because the record lacked information on Saudi Arabian laws.

Francisco "Lazaro" S. Benedicto was hired by Abdulasis & Mohamed A. Aljomaih Co., through its Philippine representative Manning International Corporation, as a truck driver for its establishment in Riyadh, Saudi Arabia, for a stipulated term of two years. He left for Saudi Arabia on December 1, 1980. On February 2, 1982, months before his contract expired, Benedicto was involved in a vehicular accident, was injured, and lost both his legs. He was confined at a hospital in Saudi Arabia until May 1982, when his employment was terminated, and he was repatriated to the Philippines in August 1982.

In October 1982, Benedicto filed a complaint with the Philippine Overseas Employment Administration (POEA) for the recovery of his salary for the unexpired portion of his contract, insurance benefits, and projected medical expenses. Despite due service of summons and several notices, his employers failed to appear or present evidence, leading the POEA to consider the case submitted for decision based on the evidence on record. On March 19, 1984, the POEA dismissed his claim for unexpired salary, finding his termination legal due to disability, but ordered the employers to pay jointly and severally P12,000.00 as total and permanent disability benefits and actual medical expenses for at least 120 days subject to verification. The employers' motion for reconsideration was denied by the NLRC on September 28, 1984, rendering the judgment executory.

Benedicto later moved for the computation of amounts due, submitting receipts of actual medical expenses. The employers opposed, arguing the receipts referred to a "Lazaro Benedicto," but the POEA Administrator overruled this, noting the names referred to the same person, and issued an alias writ of execution for P31,450.00. Benedicto sought partial reconsideration, arguing against the 120-day limitation on medical expenses. The NLRC granted this motion, setting aside the POEA Order and, based on equity and social justice, rendering a new judgment on April 15, 1988, ordering the employers to pay P65,621.03 as reimbursement of actual medical expenses from September 3, 1982, to January 26, 1985. The employers then elevated the case to the Supreme Court via a petition for certiorari.

• Estoppel: Petitioners argued that Benedicto was estopped from further claiming medical expenses because he had already been fully compensated for his injury.
• Lack of Legal Basis: Petitioners contended that the NLRC's decision increasing the award based on equity was without legal basis and unjust, as it contradicted the final and executory POEA judgment and the explicit provisions of the employment contract and labor laws.

• Finality of Judgments: Whether the NLRC could modify a final and executory judgment of the POEA to increase the award for medical expenses.
• Application of Equity: Whether the NLRC could base its modification of the award on considerations of equity and social justice rather than explicit provisions of law.

• Finality of Judgments: No. The NLRC's new judgment was void for attempting to alter a final and executory judgment, which is immutable and unalterable except for clerical errors or nunc pro tunc entries.
• Application of Equity: No. Equity cannot prevail against expressed provisions of labor laws; the NLRC's reliance on equity and social justice to increase the award was impermissible.

• Finality of Judgments: The POEA judgment of March 19, 1984, became final and executory after the NLRC denied the employers' motion for reconsideration on September 28, 1984. A final judgment becomes immutable and unalterable and may no longer be modified in any respect, even if the modification is meant to correct an erroneous conclusion of fact or law. The NLRC's "new judgment" of April 15, 1988, which increased the medical expenses from P19,450.00 to P65,621.03, could not be characterized as a correction of a clerical mistake or a nunc pro tunc entry, nor was the original POEA judgment void. Thus, the NLRC's modification was void ab initio.
• Application of Equity: The NLRC's decision to increase the award was explicitly grounded on "considerations of equity and social justice" rather than any explicit provision of law or regulation. Equity is defined as justice outside law, grounded on precepts of conscience rather than positive law. It cannot prevail against the expressed provisions of labor laws, which prescribe the specific benefits and limitations for workmen's compensation. Therefore, the NLRC's reliance on equity to override the legal limitation of 120 days for medical expenses was impermissible.

• Immutability of Final Judgments — When a final judgment becomes executory, it becomes immutable and unalterable. It may no longer be modified in any respect, even to correct perceived erroneous conclusions of fact or law, whether by the rendering court or the highest court. The only exceptions are the correction of clerical errors or nunc pro tunc entries causing no prejudice, and where the judgment is void. The Court applied this doctrine to strike down the NLRC's "new judgment" that modified the final and executory POEA order.
• Equity as Basis for Awards — Equity is justice outside law, ethical rather than jural, grounded on conscience rather than positive law. It cannot prevail against the expressed provisions of labor laws. The Court relied on this principle to invalidate the NLRC's decision to increase medical expenses based solely on equity and social justice, as it contravened the explicit legal limitations on such benefits.

• "Now, nothing is more settled in the law than that when a final judgment becomes executory, it thereby becomes immutable and unalterable." — This passage articulates the core ratio decidendi of the case, establishing the immutability of final judgments as the basis for annulling the NLRC's modification.
• "Equity has been defined as justice outside law, being ethical rather than jural and belonging to the sphere of morals than of law. It is grounded on the precepts of conscience and not on any sanction of positive law. Hence, it cannot prevail against the expressed provision of the labor laws allowing dismissal of employees for cause and without any provision for separation pay." — This defines the limits of equity in the context of labor law, explaining why the NLRC's equitable award was impermissible.

• Lichauco vs. Tan Pho, 51 Phil. 862 (1923) — Cited for the definition and object of judgments nunc pro tunc, emphasizing that such entries place on record a previously rendered judgment to make it speak the truth, not to render a new judgment or correct judicial errors.
• Philippine Long Distance Telephone Co. vs. NLRC, 164 SCRA 671 — Cited as controlling precedent for the principle that equity cannot override the expressed provisions of labor laws, specifically in the context of awarding separation pay to an employee dismissed for cause.

• Article 192, Labor Code; Sec. 2(c), Rule IX, Amended Rules on Workmen's Compensation — Applied to determine the disability benefits of no less than P12,000.00 for total and permanent disability lasting continuously for more than 120 days.
• Article 185, Labor Code; Secs. 1 and 2, Rule VIII, Amended Rules on Workmen's Compensation — Applied to determine the medical expenses actually incurred and necessary for the employee's treatment during the period of disability, subject to the expense limitation prescribed by the Commission.

Cruz, Gancayco, Griño-Aquino, and Medialdea, JJ., concur.