Title
De Ocampo vs. Radio Philippines Network, Inc.
Case
G.R. No. 192947
Decision Date
Dec 9, 2015
Petitioner sought recomputation of monetary award after final judgment; SC denied, upholding finality of decision and no exceptions applied.

Case Digest (G.R. No. 192947)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • Complainant: Melanie E. De Ocampo, who filed a complaint for illegal dismissal, unpaid salaries, damages, and attorney's fees.
    • Respondents: Radio Philippines Network, Inc. (RPN-9) and its officers, including President Cerge Remonde, News and Current Affairs Manager Rodolfo Lacuna, and Human Resources Manager Lourdes Angeles.
    • The case was docketed under NLRC-NCR Case No. 00-05-05 857-2003.
  • Procedural History and Decisions
    • May 12, 2004: Executive Labor Arbiter Manuel M. Manansala rendered a decision finding De Ocampo to have been illegally dismissed, ordering RPN-9 to pay full backwages, separation pay, and 13th month pay, and also awarding attorney’s fees.
    • February 28, 2006: The National Labor Relations Commission (NLRC) affirmed the Arbiter’s decision.
    • April 28, 2006: RPN-9’s Motion for Reconsideration before the NLRC was denied.
    • Following these decisions, respondent RPN-9 filed a Petition for Certiorari before the Court of Appeals, which led to the issuance of a temporary restraining order.
  • Timeline of Key Developments and Finality
    • Temporary Restraining Order and Lapse
      • December 11, 2006: The Court of Appeals issued a temporary restraining order preventing the enforcement of the NLRC ruling for 60 days.
      • The 60-day period lapsed without the issuance of a writ of preliminary injunction, allowing the NLRC decision to lapse into finality.
    • Entry of Judgment and Execution
      • May 27, 2006: The decision of Executive Labor Arbiter Manansala, as affirmed by the NLRC, became final and executory.
      • July 19, 2006: Entry of Judgment was made.
      • October 30, 2006 – May 7, 2007: Subsequent motions for issuance of the writ of execution were granted, and the monetary award was satisfied by deposit through a Banco de Oro check.
    • Petition for Recomputing the Award
      • After the satisfaction of the original monetary award, on September 11, 2007, De Ocampo filed a Motion for Recompute of the Monetary Award with a Motion to Issue Alias Writ of Execution, seeking an additional sum for backwages, separation pay, 13th month pay, and accrued interest.
      • December 13, 2007: The Executive Labor Arbiter denied this Motion on the ground that the prior decision had become final and executory.
      • Later, the NLRC sustained the Arbiter’s decision and further denied the Motion for Reconsideration in its December 15, 2008 Resolution.
    • Petition for Review on Certiorari
      • De Ocampo then elevated the issue by filing a Petition for Review on Certiorari before the Supreme Court under Rule 45 of the 1997 Rules of Civil Procedure.
      • The petition prayed for the reversal of the Court of Appeals’ March 5, 2010 Decision and July 8, 2010 Resolution, and sought recomputation of the monetary award.
  • Petitioner’s Actions and Inactions
    • Despite her claims, after the initial award and decisions, petitioner did not timely file the appropriate remedies to challenge the computation before her award attained finality.
    • Petitioner’s subsequent motions—for instance, the Motion to Release and later the Motion to Recompute—demonstrated her acceptance of the original award while also attempting to modify it later.
    • By not pursuing any appeal or petition during the prescribed period, petitioner effectively acquiesced to the finality of the decision.

Issues:

  • Whether petitioner Melanie E. De Ocampo is entitled to a recomputation and increase of her monetary award after the decision has attained finality and executory force.
    • Does the filing of a Petition for Certiorari under Rule 45 of the 1997 Rules of Civil Procedure stay or affect the final judgment?
    • Can a decision that has become final and executory be revisited or modified based solely on a claim of inadequate computation of monetary awards?
    • Whether petitioner’s inaction and subsequent acceptance of the judgment preclude her from asserting a right to alter the computed amounts.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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