Case Digest (G.R. No. 112955)
Facts:
The case involves the Aboitiz Shipping Employees Association (petitioner) against the Honorable Undersecretary of Labor and Employment Cresenciano Trajano and Director Bernardino Julve (respondents). The events leading to the case began in 1987 when the petitioner filed a complaint against Aboitiz Shipping Corporation (ASC) for non-compliance with the mandated minimum wage as stipulated in various Presidential Decrees (P.D. Nos. 1713 and 1751) and Wage Orders. The complaint was lodged before the National Capital Region (NCR) Regional Office of the Department of Labor and Employment (DOLE). Following the receipt of the complaint, an inspection of ASC's premises and employment records was conducted by the NCR Regional Director. After evaluating the evidence presented by both parties, the Regional Director issued an order requiring ASC to pay the complainants a total of P1,350,828.00, which represented the underpayment of a daily allowance of P2.00 per day from February 16, ...
Case Digest (G.R. No. 112955)
Facts:
Initial Complaint and Inspection
- In 1987, the Aboitiz Shipping Employees Association (petitioner) filed a complaint against Aboitiz Shipping Corporation (ASC) for non-compliance with mandated minimum wage laws, including P.D. Nos. 1713, 1751, and Wage Order Nos. 1-6.
- The National Capital Region (NCR) Regional Office of the Department of Labor and Employment (DOLE) conducted an inspection of ASC's premises and employment records.
Regional Director’s Order
- The NCR Regional Director issued an order requiring ASC to pay P1,350,828.00 representing underpayment of daily allowances from February 16, 1982, to February 15, 1985, and to continue paying the deficiency until compliance.
Appeal and Supreme Court Decision
- ASC appealed the order, but the Secretary of Labor dismissed the appeal. The Supreme Court later affirmed the order with a modification, excluding one employee (Elizardo Manuel) from the list of complainants.
Motion for Alias Writ of Execution
- On August 6, 1991, the petitioner filed a motion for an alias writ of execution, which the Regional Director granted. However, the Secretary of Labor set aside the order and created a Special Committee to recompute ASC’s liability.
Recomputation and Reduction of Award
- The Special Committee reduced the original award from P1,350,828.00 to P209,183.42 based on newly adduced evidence (company payrolls). The Secretary of Labor approved this reduction.
Petitioner’s Motion for Reconsideration
- The petitioner filed a motion for reconsideration, arguing that the order of execution was not appealable and that the Secretary of Labor had no jurisdiction to reduce the final and executory award. The motion was denied.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Finality of Judgments
- Once a judgment becomes final and executory, it can no longer be amended or altered, except for clerical errors, nunc pro tunc entries, or if the judgment is void.
Modification of Final Judgments
- The rule allowing modification of judgments after they become executory applies only when new facts or circumstances arise after the judgment’s finality. It does not apply when the modification is based on evidence that could have been presented during the original proceedings.
Jurisdiction of the Secretary of Labor
- The Secretary of Labor had no authority to reduce the final and executory award, as the liability of ASC had already been settled by the Supreme Court in a previous decision.
Policy on Litigation Finality
- The Court emphasized the importance of finality in litigation to prevent endless disputes and ensure that legal processes remain efficient and just.