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RUBEN C. JORDAN v. GRANDEUR SECURITY

FACTS:

Ruben Jordan, Valentino Galache, and Ireneo Esguerra filed complaints against Grandeur Security and Services Corp. They alleged that Grandeur Security did not pay them various benefits and illegally deducted premiums from their wages. Jordan later amended his complaint to include illegal dismissal. The Labor Arbiter (LA) ruled in favor of the complainants and ordered Grandeur Security to reinstate Jordan and award monetary claims. Grandeur Security partially appealed the decision, but did not contest the reinstatement order. The NLRC denied Grandeur Security's appeal and the decision became final and executory. Grandeur Security paid a portion of the awarded amount to Jordan, who executed a quitclaim. The LA closed the case, but Jordan appealed claiming he did not receive the return to work order.

The issue in this case is whether or not the NLRC gravely abused its discretion in altering a previous decision ordering the reinstatement of the employee.

Jordan filed a motion for execution with the NLRC, seeking to compel Grandeur Security to comply with the reinstatement order. The NLRC initially granted the motion, finding that Jordan did not receive the letter and that Grandeur Security failed to comply with the reinstatement order. The CA nullified the NLRC ruling, stating that Grandeur Security should only be cited in contempt for non-compliance with the order, but not ordered to pay backwages and separation pay.

Jordan insists that the NLRC did not alter the previous decision and argues that he is entitled to backwages and separation pay due to his non-receipt of the letter informing him to return to work. Grandeur Security argues that the NLRC had no jurisdiction to alter the previous decision, which already attained finality. It claims that Jordan is not entitled to backwages and separation pay as he was not dismissed from work and that he received the letter.

ISSUES:

  1. Whether there is a conflict between the dispositive part and the body of the decision in the Labor Arbiter's judgment.

  2. Whether the Court should harmonize the dispositive part with the whole body of the decision.

  3. What is the import of the words "reinstate" and "reinstatement" in the dispositive part of the May 27, 2008 decision?

  4. Can clerical errors in a final and executory decision be corrected?

  5. Whether or not the NLRC and the CA gravely abused their discretion in substantively altering the dispositive part of the May 27, 2008 decision.

RULING:

  1. The Court finds that there is a conflict between the dispositive part and the body of the decision in the Labor Arbiter's judgment. The dispositive part dismisses the complaint for illegal dismissal while also ordering the reinstatement of the complainant.

  2. The Court rules that the dispositive part must be harmonized with the whole body of the decision when uncertainty exists. It is necessary to scrutinize the entire decision to give effect to the intended rulings. In this case, reading the decision as a whole, it is clear that there was no illegal dismissal and that reinstatement is not warranted.

  3. The words "reinstate" and "reinstatement" in the dispositive part of the May 27, 2008 decision refer to the physical return to work of Ruben C. Jordan, as the LA found that he was not terminated from employment and did not abandon his work.

  4. Yes, clerical errors in a final and executory decision may be corrected as an exception to the principle of immutability of judgments. In this case, the word "payroll" in the dispositive part, which contradicted the LA's findings, should be deleted.

  5. Yes, the NLRC and the CA gravely abused their discretion in substantively altering the dispositive part of the May 27, 2008 decision. The NLRC's replacement of the LA's return to work order and its subsequent judgments ordering the payment of backwages, separation pay, and attorney's fees are unwarranted, unprecedented, and arbitrary. These actions effectively vacated the May 27, 2008 decision, which already found the continued existence of the employee's employment. The Court also emphasized that backwages and separation pay are mere consequences of illegal dismissal, and should only be awarded when reinstatement is no longer possible or when the continued relationship between the employer and the employee is no longer viable. The CA's nullification of the NLRC rulings is affirmed.

PRINCIPLES:

  • The court's resolution in a given issue is embodied in the decision's dispositive part.

  • When there is doubt or uncertainty between the dispositive part and the body of the decision, the Court should harmonize the two to give effect to the decision's intention.

  • Doubtful or ambiguous judgments should be interpreted in a way that does justice and avoids wrong.

  • Reinstatement without loss of seniority rights is a consequence of illegal dismissal and does not apply when there was no dismissal.

  • An order of reinstatement in the Philippines is immediately executory and self-executory, even pending appeal.

  • Courts may correct clerical errors, mistakes, or omissions in the dispositive part of a final and executory decision as an exception to the principle of immutability of judgments.

  • Under Article 217 (a) (2) and (b) of the Labor Code, the LA has original and exclusive jurisdiction over termination disputes, while the NLRC has exclusive appellate jurisdiction over these cases.

  • A definitive final judgment, however erroneous, is no longer subject to substantial change or revision, except in cases of void judgments or when circumstances transpire rendering its execution unjust and inequitable.

  • Abandonment is a matter of intention and cannot lightly be presumed from certain equivocal acts. To constitute abandonment, there must be clear proof of deliberate and unjustified intent to sever the employer-employee relationship.