G.R. No. 172149 - Session Delights Ice Cream and Fast Foods vs. Court of Appeals

The private respondent filed a complaint for illegal dismissal against Session Delights Ice Cream and Fast Foods under NLRC Case No. RAB-CAR 09-0507-00.
The Labor Arbiter rendered a decision on February 8, 2001 finding the petitioner guilty of illegal dismissal and ordered the payment of:

The NLRC affirmed the Labor Arbiter’s decision in resolutions dated May 31, 2002 and September 30, 2002.
The petitioner sought relief by filing a petition for certiorari before the Court of Appeals (CA), which was docketed as CA-G.R. SP No. 74653.
On July 4, 2003, the CA dismissed the petitioner’s petition for certiorari and, in its ruling, modified the awarded monetary benefits by deleting the awards for proportionate 13th month pay and indemnity.
The CA decision became final per the Entry of Judgment dated July 29, 2003.

In January 2004, during the execution of the final judgment, the Labor Arbiter’s Office held a pre-execution conference and submitted an updated computation which:

Included additional backwages and separation pay covering the period from March 1, 2001 to September 17, 2003;
Incorporated a proportionate amount of the private respondent’s 13th month pay.

The re-computed total amounted to P253,986.00, reflecting the additional monetary benefits.
The petitioner objected to this updated computation and appealed the Labor Arbiter’s order to the NLRC.
The NLRC, however, affirmed the Labor Arbiter’s decision in a resolution dated October 25, 2004 and denied the petitioner’s motion for reconsideration on January 31, 2005.

The petitioner then filed a petition for certiorari before the CA asserting that the NLRC acted with grave abuse of discretion by allowing a re-computation of the monetary awards.
On December 19, 2005, the CA partially granted the petitioner’s petition by deleting the proportionate 13th month pay from the computation.
In its directive, the CA ordered:

Computation of backwages from the time of salary withholding up to July 29, 2003;
Computation of separation pay from July 31, 2000 to July 29, 2003;
Re-computation of attorney’s fees, representing 10% of the total monetary awards derived from (a) and (b); and
The accrual of legal interest from July 29, 2003 until full payment.

A subsequent motion for reconsideration by the petitioner was denied by the CA in its resolution dated March 30, 2006.

The petitioner contended that a final and executory decision must be enforced only according to its dispositive portion and that the re-computation to include additional monetary awards was impermissible.
The petitioner argued that the modified labor arbiter’s decision did not mandate a computation of the monetary award up to the finality of the judgment, thus precluding any reading in of additional amounts accrued during the pendency of further litigation.
The private respondent, meanwhile, maintained that under Article 279 of the Labor Code, the monetary awards should be computed up to the finality of the decision, reflecting the full consequences of the illegal dismissal.

Whether a final and executory decision can be enforced beyond the express terms stated in its dispositive portion.
Whether the re-computation of the monetary awards—extending the calculation up to the finality of the CA decision—is legally proper and consistent with established jurisprudence.
Whether such a re-computation violates the doctrine of immutability of final judgments by altering the computation initially set forth in the labor arbiter’s ruling.
Whether the re-computation conforms with the provisions and underlying policy of Article 279 of the Labor Code regarding the payment of separation pay in lieu of reinstatement and backwages.