Metroguards Security v. Hilongo, March 9, 2015

Facts:
 
Alberto N. Hilongo was illegally dismissed. The CA held that when an appellate court affirms the Labor Arbiter's ruling, it is understood that awards due to the illegally dismissed employee shall be recomputed in order to account for the period of time that has lapsed from the rendition of the Labor Arbiter's decision up to its finality. On the basis of this, Hilongo filed a motion for issuance of writ of execution alleging that the June 11, 2013 CA Resolution had confirmed that the amount of P170,520.31 awarded by the Labor Arbiter is not sufficient, and that there is a need to compute additional monetary awards reckoned from May 1, 2010 up to April 26, 2013 or the date Hilongo presumed as the date of finality of the decision. The Labor Arbiter directed the issuance of a writ of execution and ruled that the award of P170,520.31 as stated in the Labor Arbiter's Decision dated April 30, 2010 prevails.
 
 
Issue:
Whether or not the CA erred in ordering the re-computation of Hilongo's monetary awards? - NO
 
 Held:
No essential change is made by a recomputation as this step is a necessary consequence that flows from the nature of the illegality of dismissal declared by the Labor Arbiter in that decision. A recomputation (or an original computation, if no previous computation has been made) is a part of the law — specifically, Article 279 of the Labor Code and the established jurisprudence on this provision — that is read into the decision. By the nature of an illegal dismissal case, the reliefs continue to add up until full satisfaction, as expressed under Article 279 of the Labor Code.
 
The recomputation of the consequences of illegal dismissal upon execution of the decision does not constitute an alteration or amendment of the final decision being implemented. The illegal dismissal ruling stands; only the computation of monetary consequences of this dismissal is affected, and this is not a violation of the principle of immutability of final judgments.
 
We thus cannot agree with petitioners' contention that a decision that has acquired finality becomes immutable and unalterable. The re-computation of the consequences of illegal dismissal upon execution of the decision does not constitute an alteration or amendment of the final decision being implemented. The illegal dismissal ruling stands; only the computation of monetary consequences of this dismissal is affected, and this is not a violation of the principle of immutability of final judgments.