Title
Blanco vs. Philippine Automotive Manufacturing Corp.
Case
G.R. No. 147941
Decision Date
Mar 16, 2005
Nestor Blanco's illegal dismissal case against PAMCOR led to a final NLRC decision, but subsequent motions for additional backwages and regular employment were denied due to the judgment's finality. Supreme Court upheld the decision, emphasizing immutability of final judgments.
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Case Digest (G.R. No. 147941)

Facts:

  1. Initial Complaint and Labor Arbiter's Decision:
    Nestor V. Blanco filed a complaint for illegal dismissal against Philippine Automotive Manufacturing Corporation (PAMCOR). The Labor Arbiter ruled in favor of Blanco, declaring his dismissal illegal and ordering PAMCOR to reinstate him and pay backwages of P24,398.40, plus attorney's fees.

  2. NLRC Decision:
    The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision but deleted the award of attorney's fees. PAMCOR's motion for reconsideration was denied, and the decision became final and executory.

  3. Execution of Judgment:
    On May 15, 1997, the Labor Arbiter issued a writ of execution. PAMCOR complied by paying Blanco the backwages and reinstating him as a probationary machinist effective August 1, 1997.

  4. Blanco's Subsequent Motions:
    Despite the finality of the NLRC decision, Blanco filed motions for (1) recomputation of backwages covering March 7, 1995, to August 1, 1997, and (2) reinstatement as a regular employee. The Labor Arbiter granted both motions, ordering PAMCOR to pay additional backwages of P99,995.04 and reinstate Blanco as a regular machinist.

  5. NLRC Reversal and Court of Appeals Decision:
    PAMCOR appealed to the NLRC, which reversed the Labor Arbiter's order. Blanco filed a petition for certiorari with the Court of Appeals, which dismissed his petition, ruling that the NLRC decision had become final and executory.

  6. Petitions to the Supreme Court:
    Both Blanco and PAMCOR filed petitions for review with the Supreme Court. Blanco sought recognition as a regular employee and additional backwages, while PAMCOR contested the Court of Appeals' nullification of the NLRC's second decision.

Issue:

  1. Whether Nestor Blanco should be considered a regular employee.
  2. Whether Blanco is entitled to additional backwages of P99,995.04.
  3. Whether the Court of Appeals erred in nullifying the NLRC's second decision.

Ruling:

The Supreme Court denied both petitions. It affirmed the Court of Appeals' decision, holding that the NLRC's July 18, 1996 decision had become final and executory. The Court ruled that the Labor Arbiter overstepped his jurisdiction by modifying the final judgment, which was no longer subject to change or revision.

Ratio:

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