Nacar vs. Gallery Frames, August 13, 2013

Facts:
On January 24, 1997, Dario Nacar got dismissed by his employer, Gallery Frames. He filed a complaint; the Labor Arbiter ruled that the petitioner was dismissed without just cause. Computation for the separation pay and back wages were made and it amounted to Php 158,919.92. The respondent sought an appeal to the NLRC, CA, and Supreme Court, but they were all dismissed, thus the judgment became final on April 17, 2002. During the execution of the final judgment, the petitioner filed a motion for the re-computation of the damages.
 
The amount previously computed includes the separation pay and back wages up to the time of his dismissal. The petitioner argued that the damages should cover the period until the date of final judgment. A re-computation was made and the damages were increased to 471,320.31. Respondent prayed for the quashal of such motion on the ground that the judgment made by the SC is already final and the amount should not be further altered. Petitioner also filed another motion asking the court to order the respondent to pay the appropriate legal fees.

Issue:
Whether or not a subsequent correction of the damages awarded during the final judgment of the Supreme Court violates the rule on immutability of judgments.

​Held:
The Supreme Court ruled that a correction in the computation of the damages does not violate the rule on immutability of judgments. The final decision made by the Supreme Court to award the petitioner with damages with regards to the dismissal without justifiable cause can be divided into two important parts. One is the finding that an illegal dismissal was indeed made. And the other is the computation of damages.
 
According to a previous case of Session Delights Ice Cream and Fast Foods v. Court of Appeals, the Supreme Court held that the second part of the decision - being merely a computation of what the first part of the decision established and declared - can, by its nature, be recomputed. 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. Interest of the damages from the date of final judgment until full payment.