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 Summary (G.R. No. 192947)

Applicable Law

The applicable law governing this case is the 1987 Philippine Constitution as well as the 1997 Rules of Civil Procedure and the 2005 Rules of Procedure of the National Labor Relations Commission.

Case Background

De Ocampo filed a complaint for illegal dismissal, unpaid salaries, damages, and attorney's fees against RPN-9. The case was registered as NLRC-NCR Case No. 00-05-05857-2003. On May 12, 2004, Executive Labor Arbiter Manuel M. Manansala issued a decision declaring her dismissal illegal, ordering RPN-9 to pay her full back wages and separation pay, while the impleaded officers were absolved from liability. The amounts awarded were subsequently computed by the Arbitration Branch’s Examination and Computation Unit.

Judicial Proceedings and Rulings

The National Labor Relations Commission (NLRC) affirmed Executive Labor Arbiter Manansala's decision on February 28, 2006 and denied RPN-9's motion for reconsideration on April 28, 2006. RPN-9 then petitioned before the Court of Appeals, which issued a temporary restraining order preventing the NLRC from enforcing its ruling for 60 days. However, this period lapsed without a subsequent writ of preliminary injunction being issued, leading to the finality of the initial ruling on May 27, 2006.

Petitioner’s Subsequent Actions

After the Entry of Judgment on July 19, 2006, De Ocampo sought a writ of execution. On October 30, 2006, the NLRC granted her motion, resulting in a Writ of Execution issued on May 7, 2007, directing RPN-9 to pay a total of ₱410,826.85. This amount was satisfied through a bank deposit on August 22, 2007, and De Ocampo quickly moved for the release of the amount.

Motion for Recalculation of Monetary Award

Despite having received the full satisfaction of the original award, De Ocampo filed a motion on September 11, 2007, seeking to recompute her monetary award to include additional back wages, separation pay, and 13th month pay, along with 12% interest per annum on the original award. Executive Labor Arbiter Manansala denied her motion on December 13, 2007, asserting that the previous decision had become final and executory.

Court of Appeals Decisions

The petition for certiorari filed by De Ocampo before the Court of Appeals to challenge the NLRC decisions was dismissed on March 5, 2010. Consequently, her motion for reconsideration was also denied on July 8, 2010.

Finality of Judgment and Legal Principles

The core legal issue settled by the Supreme Court was whether De Ocampo could still seek a recomputation and increase in her monetary award. It was held that she could not, as the judgment rendered by Executive Labor Arbiter Manansala had attained finality, thus precluding any alterations or modifications. As established in prior rulings, once a judgment becomes final, it cannot be disturbed even if the modification pertains to correcting what is perceived to be an error. The only exceptions apply to clerical corrections, adjustments based on circumstances post-finality that render execution inequitable, or void judgments.

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