Case Digest (G.R. No. 180188)
Facts:
C-E Construction Corporation (petitioner) is a corporation engaged in general construction, which employed Raymundo Hernandez (respondent) as an electrician and carpenter starting January 17, 1996, for the Filinvest Festival Supermall project. The employment contract explicitly stated that Hernandez's employment was co-terminus with the project. On December 17, 1996, Hernandez was dismissed by the petitioner, who claimed that the initial phase of the project had been completed. In response, Hernandez filed a complaint for illegal dismissal, seeking reinstatement, backwages, and attorney's fees. The petitioner contended that Hernandez was a project employee and that his dismissal was valid due to the completion of the project phase for which he was hired.
On February 16, 1998, the labor arbiter ruled that Hernandez's dismissal was illegal, ordering his reinstatement and awarding him backwages amounting to P56,833.29, along with P50,000.00 in moral damages and at...
Case Digest (G.R. No. 180188)
Facts:
Employment and Dismissal
- Petitioner C-E Construction Corporation (CECC) is a corporation engaged in general contract construction. It employed respondent Raymundo Hernandez as an electrician and carpenter on January 17, 1996, for its Filinvest Festival Supermall project. The employment contract stated that Hernandez's employment was co-terminus with the project.
- On December 17, 1996, CECC dismissed Hernandez, claiming that the initial phase of the project had been completed.
Complaint and Labor Arbiter Decision
- Hernandez filed a complaint for illegal dismissal, seeking reinstatement, backwages, and attorney's fees.
- On February 16, 1998, the Labor Arbiter ruled in favor of Hernandez, declaring the dismissal illegal and ordering CECC to:
- Reinstate Hernandez without loss of seniority rights.
- Pay backwages amounting to P56,833.29.
- Pay moral damages of P50,000.00.
- Pay attorney's fees equivalent to 10% of the total award.
NLRC Decision
- CECC appealed to the National Labor Relations Commission (NLRC), which partially reversed the Labor Arbiter's decision by deleting the awards for moral damages and attorney's fees.
- CECC's motion for reconsideration was denied.
Court of Appeals and Supreme Court
- CECC filed a petition for certiorari with the Court of Appeals, which denied the petition, finding no evidence that the project's initial phase was completed and noting the lack of notice or hearing for Hernandez.
- The Supreme Court denied CECC's petition for review on certiorari, and the decision became final on February 9, 2001.
Re-computation of Backwages
- Hernandez filed an omnibus motion for re-computation of backwages and issuance of a writ of execution. The Labor Arbiter issued an order on January 28, 2002, awarding additional backwages.
- CECC appealed to the NLRC, arguing that wages Hernandez could have earned during the pendency of the case should be deducted and that backwages should only cover the project's duration.
- The NLRC affirmed the Labor Arbiter's decision, and CECC's motion for reconsideration was denied.
- CECC filed a petition for certiorari with the Court of Appeals, which dismissed the petition, stating that the computation of backwages is a factual issue not subject to certiorari.
Issue:
- Whether Hernandez is a regular employee or a project employee.
- Whether the computation of backwages should cover only the unexpired portion of the project or the entire period until reinstatement.
- Whether the final and executory judgment can be modified through a petition questioning the order of execution.
Ruling:
The Supreme Court denied CECC's petition, affirming the Court of Appeals' decision. The Court held that:
- Hernandez is a regular employee, as ruled by the Labor Arbiter, NLRC, and Court of Appeals.
- The computation of backwages is consistent with the final and executory judgment, and no modification is allowed.
- Final judgments cannot be altered except for clerical errors, and the order of execution issued by the Labor Arbiter is valid.
Ratio:
- Regular Employment: Hernandez is a regular employee, not a project employee, as determined by the Labor Arbiter and NLRC. The Court of Appeals' statement that Hernandez was a project employee is an obiter dictum and not part of the dispositive portion of the decision.
- Finality of Judgment: Once a judgment becomes final and executory, it cannot be amended or altered, except for clerical errors. The order of execution must conform to the final judgment.
- Backwages: The computation of backwages for an illegally dismissed employee covers the period from dismissal until actual reinstatement, not just the duration of the project.
- No Grave Abuse of Discretion: The NLRC and Labor Arbiter did not commit grave abuse of discretion in their decisions, and the Court of Appeals correctly dismissed CECC's petition.
Conclusion:
The Supreme Court upheld the finality of the judgment and denied CECC's petition, affirming that Hernandez is a regular employee entitled to full backwages until reinstatement. The Court emphasized that final judgments must be respected to ensure the stability of judicial decisions.