Tag Fibers, Inc. vs. NLRC

A final and executory judgment cannot be modified or varied by the court or quasi-judicial body that rendered it, even during execution proceedings, because the finality of a decision is a jurisdictional event. The Labor Arbiter's authority to execute a judgment is merely ministerial and does not include the power to alter the dispositive portion of a final decision.

Petitioner Tag Fibers, Inc. absorbed respondents as regular employees from its predecessors in August 1979. The company terminated respondents in the second week of February 1983 due to losses. Respondents were re-hired as piece-rate workers the following day, but petitioners prohibited them from working in July 1983 upon learning that respondents had filed a complaint for violation of the Minimum Wage Law.

• Employment and Termination: In August 1979, petitioner Tag Fibers, Inc. absorbed respondents from its predecessors as regular and permanent employees. In the second week of February 1983, petitioners terminated all respondents due to company losses.
• Re-hiring and Subsequent Prohibition: On February 11, 1983, petitioners re-hired respondents as piece-rate workers effective the day after their termination. On July 25, 1983, when petitioners learned that respondents had filed a complaint with the Regional Director for violation of the Minimum Wage Law, petitioners prohibited respondents from working.
• Illegal Dismissal Complaint: On August 22, 1983, respondents filed a complaint for illegal dismissal with reinstatement and payment of backwages and other benefits. On January 11, 1985, Labor Arbiter Felipe T. Garduque III ordered petitioners to reinstate respondents and pay P10,858.68.
• Finality of Judgment: Petitioners appealed to the NLRC, which dismissed the appeal on February 17, 1986. The NLRC denied petitioners' motion for reconsideration on July 30, 1986, rendering the decision final and executory. Petitioners subsequently filed a certiorari petition with the Supreme Court, which dismissed it on October 5, 1987.
• Execution Proceedings: On February 15, 1993, Labor Arbiter Reynoso A. Belarmino issued a writ of execution for the 1985 decision. Petitioners paid the full monetary award of P10,858.68 but refused to reinstate respondents. Respondents pressed for backwages not provided in the Garduque decision, prompting the Labor Arbiter to set a conference.
• Modification by Labor Arbiter and NLRC: On July 12, 1993, Labor Arbiter Belarmino found that a strained relationship existed and granted respondents P27,300.00 each as separation pay. On April 19, 1995, the NLRC modified the resolution but still ordered petitioners to pay reinstatement salary and separation pay. The NLRC denied petitioners' motion for reconsideration on May 26, 1995.

• Petitioners maintained that the monetary aspect of the January 11, 1985 judgment had been satisfied.
• Petitioners argued that the Labor Arbiter's authority to enforce judgment is merely ministerial; thus, the Labor Arbiter cannot modify or vary a final and executory decision of the NLRC.

• Procedural Issues: Whether the Labor Arbiter and the NLRC had jurisdiction to modify a final and executory judgment by granting separation pay and additional backwages during execution proceedings.
• Substantive Issues: N/A

• Procedural: The Court held that the Labor Arbiter and the NLRC acted without jurisdiction. Under Rule 39, Section 6 of the Rules of Court, which applies suppletory to labor cases, a judgment may be executed on motion within five years from the date it becomes final and executory. Because the 1985 decision became final in 1986, the Labor Arbiter had no jurisdiction to convene a conference in 1993 to modify the judgment. The finality of a decision is a jurisdictional event that cannot depend on the convenience of a party. By ordering separation pay from February 1983 to June 1993, the NLRC modified its own final judgment and acted without jurisdiction.
• Substantive: N/A

• Finality of Judgments — A decision that has become final and executory can no longer be modified or varied by the court or quasi-judicial body that rendered it. The finality of a decision is a jurisdictional event. The Court applied this to hold that the Labor Arbiter and NLRC lost jurisdiction to alter the 1985 decision by adding separation pay and backwages years after it became final.
• Ministerial Duty of Execution — The Labor Arbiter's authority in execution proceedings is merely ministerial. The Court applied this to emphasize that the Labor Arbiter cannot go beyond the terms of the final judgment.

• "The finality of a decision is a jurisdictional event that cannot be made to depend on the convenience of a party."

• Camacho vs. Court of Appeals, 287 SCRA 611 [1998] — Cited for the rule that a judgment may be executed on motion within five years from entry, after which it requires an action.
• Associated Anglo-American Tobacco Corporation vs. NLRC, 306 SCRA 380, 385 [1999] — Cited for the rule that the Rules of Court are applicable to labor cases in a suppletory capacity.
• Philippine Rabbit Bus Lines, Inc. vs. NLRC, 306 SCRA 151 [1999] — Cited for the doctrine that the finality of a decision is a jurisdictional event that cannot be made to depend on the convenience of a party.

• Rule 39, Section 6, 1964 Revised Rules of Court — Provides that a judgment may be executed on motion within five (5) years from the date of its entry or from the date it becomes final and executory. After such time, and before it is barred by the statute of limitations, a judgment may be enforced by action. Applied to determine that the Labor Arbiter lacked jurisdiction to modify the judgment years after it became final.

Davide, Jr., C.J., (Chairman), Puno, Kapunan, and Ynares-Santiago, JJ.