Labor Judgment that has been Executed and Fully Satisfied Cannot be Recomputed
Labor case, no matter how complex has to come to an end. Execution is the final stage of litigation, the end of the suit. (See Mt. Carmel College vs. Resuena, 561 Phil. 620, 645 (2007) citing Torres vs. NLRC, 386 Phil. 620-645 (2007))
The labor laws dictate that backwages must be computed from the time the employee was unjustly dismissed until his or her actual reinstatement or upon payment of his or her separation pay if reinstatement is no longer feasible.
Hence, insofar as accrued backwages and other benefits are concerned, the employer’s obligation to the employee continues to accumulate until he actually implements the reinstatement aspect of the final judgment or fully satisfies the monetary award in case reinstatement is no longer possible.
In the case of Tan vs. Dagpin (G.R. No. 212111, January 15, 2020), the employee sued the employer, Tan, for illegal dismissal. The Labor Arbiter declared the employee illegally dismissed and ordered the employer to pay separation pay, backwages, service incentive leave pay, 13th month pay, moral and exemplary damages, and attorney’s fees.
The employee still won the case with the National Labor Relations Commission (NLRC) when Tan appealed. Tan went to the Court of Appeals which issued the Temporary Restraining Order (TRO). An Entry of Judgment was issued on the NLRC Resolution. The employee filed with the Executive Labor Arbiter (ELA) a Motion to Admit Computation and Issuance of Writ of Execution where she computed her separation pay, backwages, and other claims up to the finality of judgment on January 10, 2005 in the total sum of PhP1,080,566.66.
After the TRO issued by the CA had expired, the ELA ordered the release of employer’s cash bond in partial satisfaction of judgment. Thereafter, the Writ of Execution was issued, which was fully enforced and satisfied.
On the petition filed by the employer (Tan) with the CA, the court dismissed the petition for lack of merit. The Supreme Court (SC) also dismissed the petition when Tan appealed via petition for review on certiorari.
Afterwards, the employee filed another Motion for Approval of Computation and Issuance of Writ of Execution seeking additional increments to her monetary award. She claims that her backwages and separation pay should be computed up to August 21, 2008 when the Court’s resolution on the issue of illegal dismissal became final and executory. The employer opposed this claiming that the principle of non-immutability of judgment applies or that the final and executory judgment cannot anymore be modified.
The SC held that although the employer formally opposed the employee’s claims all the way up to the SC, she, nonetheless, yielded to the execution of judgment sought by the employee way back in 2005 at the ELA’s level. Inasmuch as the employer had already satisfied the final monetary benefits awarded to the employee, the latter may not ask for another round of execution, lest, it violates the principle against unjust enrichment.
The SC emphasized that there is no additional increment which accrued to the employee by reason of the SC’s Resolution which did not modify, let alone, alter the long executed judgment of the NLRC.
It is settled that a final judgment may no longer be altered, amended, or modified, even if the alteration, amendment or modification is meant to correct a perceived error in conclusions of fact and law and regardless of what court renders it. More so when, as in this case, such final judgment had already been executed and fully satisfied.
The employee’s receipt of the full separation pay and other benefits effectively severed the employer-employee relationship. From that point up until the finality of the Court’s Resolution, she was no longer an employee of Tan. Hence, she has no more right to demand further benefits as such.