De Ocampo Vs RPN
De Ocampo Vs RPN
De Ocampo Vs RPN
as it becomes final and executory; “nothing is more settled in law.” Once a case is decided with
finality, “the controversy is settled and the matter is laid to rest.” Accordingly, a final judgment
may no longer be modified in any respect “even if the modification is meant to correct what is
perceived to be an erroneous conclusion of fact or law, and regardless of whether the
modification is attempted to be made by the court rendering it or by the highest court of the
land.” Once a judgment becomes final, the court or tribunal loses jurisdiction, and any modified
judgment that it issues, as well as all proceedings taken for this purpose, is null and void.
SECOND DIVISION
LEONEN, J.;
FACTS:
De Ocampo was the complainant in a case for illegal dismissal. Executive Labor Arbiter
rendered a Decision finding De Ocampo to have been illegally dismissed. The National Labor
Relations Commission affirmed the Decision of Executive Labor Arbiter, RPN-9's Motion for
Reconsideration was denied. RPN-9 then filed before the Court of Appeals a Petition for
Certiorari with prayer for temporary restraining order and/or preliminary injunction. Court of
Appeals issued a temporary restraining order preventing the National Labor Relations
Commission from enforcing its ruling for a period of 60 days. The sixty-day period lapsed
without a writ of preliminary injunction being subsequently issued by the Court of Appeals.
Accordingly, the ruling of Executive Labor Arbiter, as affirmed by the National Labor Relations
Commission, became final and executor and an Entry of Judgment was then issued. De Ocampo
then filed a Motion for Issuance of Writ of Execution which the National Labor Relations
Commission granted. The full satisfaction of the original award notwithstanding, De Ocampo
filed a Motion to Recompute the Monetary Award with Motion to Issue Alias Writ of Execution.
In the Motion, De Ocampo sought the increase of the monetary award given her.
Executive Labor Arbiter denied De Ocampo's Motion to Recompute the Monetary Award with
Motion to Issue Alias Writ of Execution on the ground that the Decision fixing the amounts of
the monetary award due to De Ocampo had become final and executory.
ISSUE:
May De Ocampo still seek a recomputaion of and an increase in the monetary award
given her?
HELD:
NO
This elementary rule finds basis in "public policy and sound practice that at the risk of
occasional error, the judgment of courts and the award of quasi-judicial agencies must become
final at some definite date fixed by law." Basic rationality dictates that there must be an end to
litigation. Any contrary posturing renders justice inutile and reduces to futility the winning
party's capacity to benefit from a resolution of the case.
The only exceptions to the general rule are the correction of clerical errors, the so-
called nunc pro tunc entries which cause no prejudice to any party, void judgments, and
whenever circumstances transpire after the finality of the decision rendering its execution unjust
and inequitable. Consistent with the principle of finality of judgments, it follows that no appeal
may be taken from orders of execution of judgments.