G.R. No. 20479 - Yu Cong Eng vs. Trinidad

The case involves Metroguards Security Agency Corporation (formerly known as Bee Guards Corporation) and Ms. Milagros T. Chan (petitioners) versus Alberto N. Hilongo (respondent).
The Labor Arbiter, in its Decision dated April 30, 2010 (NLRC NCR-10-14411-09), ruled that Hilongo was illegally dismissed and awarded backwages, separation pay computed as one month pay per year of service, and attorney’s fees amounting to 10% of the computed award.
The award included detailed computations on basic salary, 13th month pay, service incentive leave, and separation pay for the period the employee rendered service.

On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s ruling (Decision dated September 30, 2010 and Resolution dated November 23, 2010).
Hilongo, aggrieved by the reversal, filed a petition for certiorari before the Court of Appeals (CA), resulting in the CA Decision dated September 7, 2012 that reinstated the original ruling of the Labor Arbiter.
Petitioners (Metroguards Security Agency Corporation and Milagros T. Chan) sought reconsideration before the CA, which was denied as reflected in the Resolution dated March 26, 2013.

Following the denial of petitioners’ reconsideration, Hilongo filed motions for entry of judgment and for clarification of the CA Decision/Resolution, arguing that the computation should include additional monetary awards from May 1, 2010, to the effective date of finality.
The CA, in its Resolution dated June 11, 2013, granted the motion for entry of judgment and observed that a re-computation was necessary to account for the period lapsed from the Labor Arbiter’s decision until finality.
The CA, basing its reasoning on established jurisprudence and Article 279 of the Labor Code, held that the monetary consequences in an illegal dismissal case continue to accrue until full satisfaction of the award.

After the entry of judgment, Hilongo sought issuance of a writ of execution, requesting additional computations for backwages and separation pay from either May 1, 2010 to April 26, 2013 (or to the presumed finality date).
The Labor Arbiter, in an Order dated October 29, 2013, directed that the original award (of P170,520.31) as computed on April 30, 2010 would prevail.
Hilongo’s subsequent extraordinary remedy petition before the NLRC was dismissed (Decision dated November 29, 2013 and Resolution dated January 16, 2014), prompting him to file a petition for certiorari before the CA.

In the CA Decision dated July 22, 2014, the petition was granted in part and the NLRC decisions were set aside.
The CA ordered the Labor Arbiter to re-compute the total monetary benefits due to Hilongo, explicitly incorporating:

Additional backwages and separation pay from May 1, 2010, to the date the decision became final and executory.
Interest at 12% per annum computed appropriately from the finality date (initially held as June 11, 2013 by the CA) until June 30, 2013 and at 6% per annum thereafter.

Notably, the CA clarified that although the core illegal dismissal ruling stands, the computation of monetary awards is subject to continuous accrual until full satisfaction.

A controversy arose regarding the precise date of finality of the Labor Arbiter’s decision; while the CA at one point considered June 11, 2013 as the finality date, it later found that the decision actually became final and executory on April 26, 2013.
This discrepancy led to an erroneous computation of additional wages, separation pay, and the corresponding legal interest, necessitating modifications in the final awards.

Whether the Court of Appeals erred in ordering the re-computation of Hilongo’s monetary awards despite the finality of the Labor Arbiter’s decision.

Can re-computation of backwages and separation pay be mandated even after the decision has acquired finality?
Does the re-computation alter the immutable nature of a final decision or merely adjust the monetary consequences pursuant to Article 279 of the Labor Code?
What is the correct finality date applicable for computing additional monetary awards and interest, and how does this affect the overall computation?