MANNING INTERNATIONAL CORPORATION/ABDULASIS & MOHAMED A. ALJOMAIH vs. NATIONAL LABOR RELATIONS COMMISSION and FRANCISCO "LAZARO" S. BENEDICTO.
- G.R. Number: G.R. No. 83018
- Promulgated: 1991-03-13
- Ponente: Narvasa, J.
Doctrine
A final and executory judgment is immutable and unalterable; it cannot be modified except for correction of clerical errors, nunc pro tunc entries that cause no prejudice, or where the judgment is void.
An administrative or quasi-judicial body (here, the NLRC) cannot vary the disposition of a final and executory decision of the POEA; any attempt to render a 'new judgment' altering such decision is void as to that effect.
Equity and considerations of social justice cannot be invoked to override explicit statutory provisions of the labor laws (e.g., denial of separation pay where dismissal is for cause).
Facts
Francisco Benedicto (a.k.a. Lazaro Benedicto) was hired by Abdulasis & Mohamed A. Aljomaih Co. through Manning International Corporation as a truck driver in Riyadh for a two-year term and departed for Saudi Arabia on 1 December 1980.
On 2 February 1982 Benedicto suffered a vehicular accident in Saudi Arabia, lost both legs, was hospitalized until about May 1982, and his employment was terminated; he was repatriated in August 1982.
The POEA issued a final and executory order on 8 July 1986; subsequently the NLRC rendered a decision on 15 April 1988 that altered the POEA disposition.
Issues
Whether the NLRC could modify the final and executory order of the Philippine Overseas Employment Administrator (POEA).
Whether the NLRC's decision of 15 April 1988 is void for attempting to vary a final POEA decision and for resting on considerations of equity and social justice contrary to law.
Ruling
The petition is granted; the writ of certiorari is issued annulling and setting aside the NLRC Decision dated 15 April 1988 and reinstating and affirming the POEA Order dated 8 July 1986.
The NLRC's ‘new judgment’ is void ab initio insofar as it attempts to vary the disposition of the final and executory POEA decision and thus is inefficacious to change the Administrator's decision.
The NLRC improperly grounded its alteration on 'considerations of equity and social justice,' which cannot prevail against explicit provisions of the labor laws disallowing separation pay when dismissal is for cause.
Keywords
G.R. No. 83018, Manning International Corporation, Abdulasis & Mohamed A. Aljomaih, National Labor Relations Commission (NLRC), Francisco "Lazaro" S. Benedicto, employment contract, vehicular accident, Philippine Overseas Employment Administration (POEA), salary for unexpired portion of contract, insurance benefits, medical expenses, total and permanent disability benefit, workmen's compensation benefits, motion for reconsideration and new trial, newly discovered evidence, alias writ of execution, certiorari, equity and social justice, Philippine law on disability benefits, service-connected illness, injuries or death