8/23/2020
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replacing their national currencies with the Euro.[32] After its gradual adaptation to the
new economic and monetary regime, its national currency, the Irish Pound, finally
departed and ceased to be legal tender on February 9, 2002.[33] Inasmuch as the
monetary award in this case has been fixed in the Irish Pound but to be paid in its
Philippine Peso equivalent, the Labor Arbiter, in issuing the subject writ of execution on
July 31, 2012, has made a practical, consequential and logical call when she recomputed and converted the final Decision's money award into the prevailing currency
that replaced the previous - not to say demonetized and, hence, obsolete and worthless
currency, but still payable to Gutierrez in Philippine Peso equivalent.
The power of the Labor Arbiter to make, at the first instance, a computation of
monetary award in an illegal dismissal case is sanctioned by the NLRC Rules of
Procedure.[34] Implied from this original computation is its currency up to the finality of
the decision.[35] Indeed, on one hand, had the case purely involved an employee's
claim for a specific sum of money, the computation would carry such a continuing
currency that any adjustment or change might only be on the interest that would run
from the finality of the decision until full satisfaction of the judgment obligation. On the
other hand, in a claim that relates to status, such as in illegal dismissal cases, what is
principally implemented is the declaratory finding on the status, rights and obligations
of the parties, and the monetary consequence only follows as a mere incidental
component of said finding.[36]
That the Labor Arbiter has been impelled to make an allowance for the conversion of
the money award to happen inspite of the demonitization of the Irish Pound, is well in
accord with Republic Act No. 8183.[37] This law authorizes obligations incurred in
foreign currency to be discharged in our local money at the prevailing rate of exchange
at the time of payment. In other words, because it is just and fair to preserve the real
value of the foreign exchange-incurred obligation to the date of its payment,[38] it is
just as much legal and logical to take into account the fact that the exchange rate at
the time of execution was already measured in terms of the Euro.
At any rate, Session Delights Ice Cream, and Fast Foods v. Court of Appeals[39]
instructs that a re-computation of the monetary award is indeed part of the law that is
read into the decision. The re-computation of the consequences of an illegal dismissal,
to accommodate the reliefs that continue to add on until full satisfaction of the award,
even upon execution of the decision does not constitute an alteration or amendment of
the final decision being implemented. Indeed, the ruling on the illegality of the
dismissal stands, and only the computation of the monetary consequences must adapt
to changes albeit without running foul to the principle of immutability of a final
judgment.[40]
With approval, we quote the observation made by the Court of Appeals on this matter:
The Writ of Execution did not alter the essential particulars of the judgment
to be executed. The original fallo provides that the money judgment is
payable in Philippine Peso at the rate of exchange prevailing at the time of
payment. To be able to convert the said money judgment from Irish Pound
to Philippine Peso, it is necessary to first convert it to Euro since Irish Pound
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