Cosmos Foundry Shop Workers Union v. Lo Bu
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from an unfair labor practice case filed by the Cosmos Foundry Shop Workers Union against Ong Ting, the owner of Cosmos Foundry Shop and later New Century Foundry Shop. Following a judgment in favor of the union, efforts to execute the judgment were repeatedly frustrated by Ong Ting, who, after rejecting settlement offers, allegedly sold his business to respondent Lo Bu through a deed of absolute sale. The Court of Industrial Relations (CIR) found this sale to be fictitious and intended to circumvent the judgment. 2. Procedural History: The CIR issued an alias writ of execution to satisfy the judgment, leading to the levy of personal properties of the New Century Foundry Shop. Lo Bu filed motions to recall the writ, asserting lack of jurisdiction and failure to post an indemnity bond, which were denied by the CIR. Lo Bu appealed these denials via certiorari to the Supreme Court (G.R. No. L-36636), which was denied. Subsequently, Lo Bu filed a replevin suit in the Court of First Instance of Manila for the same properties. The union moved to dismiss this suit, arguing Lo Bu was a fictitious buyer, and the Court of First Instance dismissed the complaint. The Court of Appeals, however, initially dismissed the union's appeal from this dismissal but later reinstated it, prompting the present petition. 3. The Petition: This petition for certiorari and prohibition assails the Court of Appeals' jurisdiction to entertain Lo Bu's appeal from the dismissal of his replevin suit. Petitioners argue that the replevin suit was a mere subterfuge to frustrate the execution of the labor dispute judgment, which had already been affirmed by the Supreme Court. They contend that the Court of Appeals' reinstatement of the appeal, despite the established findings of fictitious sale and bad faith by the Supreme Court in G.R. No. L-36636, constitutes a grave abuse of discretion and violates the principle of the law of the case. The petition seeks to nullify the Court of Appeals' order and prohibit it from further proceeding with the appeal.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion in reinstating the appeal from the dismissal of the replevin suit. Whether the replevin suit was a legitimate action or a mere subterfuge to delay the execution of a labor judgment. Whether the doctrine of the 'law of the case' applies to the present proceedings.
Ruling
The Supreme Court granted the writ of certiorari and prohibition, nullified and set aside the order of the Court of Appeals reinstating the appeal, and perpetually restrained the Court of Appeals from taking further action on the appeal, except to dismiss it. Costs were tripled.
Ratio Decidendi
On the issue of the Court of Appeals' jurisdiction and the nature of the replevin suit: The Court found that the replevin suit filed by Lo Bu was a clear subterfuge designed to frustrate the execution of a final judgment in an unfair labor practice case. The Court noted that Lo Bu's motions before the CIR and his subsequent certiorari petition to the Supreme Court (G.R. No. L-36636) were all denied, indicating a pattern of delaying tactics. The CIR itself had previously declared the sale of the New Century Foundry Shop to Lo Bu as fictitious, intended to circumvent the judgment. The Court emphasized that the Court of Appeals gravely abused its discretion in reinstating the appeal from the CFI's dismissal of the replevin suit, as this action would only serve to further delay the vindication of the labor union's rights. The Court reiterated that it is about time that a halt be called to such schemes that defeat labor's just claims, which would be repugnant to the principles of social justice and protection to labor. On the application of the 'law of the case' doctrine: The Court held that the doctrine of the 'law of the case' was firmly applicable. Lo Bu himself was the petitioner in G.R. No. L-36636, where this Court denied his petition for certiorari, thereby affirming the CIR's denial of his motions to recall the writ of execution. This prior ruling by the Supreme Court on the same issues, particularly concerning the validity of the sale and the enforcement of the writ, became the law of the case. The Court cited numerous precedents, including Cruz v. Philippine Association of Free Labor Unions, Mangayao v. De Guzman, Kabigting v. Acting Director of Prisons, Compagnie Franco-Indochinoise v. Deutsche-Australische Dampschiffs Gesellschaft, People v. Olarte, and Sanchez v. Court of Industrial Relations, to underscore that a decision of the Supreme Court, once final, is binding on all inferior courts and cannot be altered or modified. Lo Bu could not plead ignorance, as he was a party to the previous certiorari proceeding, and his petition was dismissed on the merits of the facts found, which included his bad faith in the alleged sale. On the alleged adequate remedy at law: While generally a plea for an adequate remedy in the ordinary course of law is considered, the Court found it inapplicable in this instance due to the "sad plight" of the petitioner labor union and the "schemes utilized by respondent Lo Bu." Allowing further proceedings in the Court of Appeals would perpetuate the delay and contravene the fundamental principles of social justice and protection to labor. The Court stressed that the satisfaction of a judgment that ought to have been enforced years ago should not be further delayed by such tactics. The Court's power to issue certiorari and prohibition is precisely to prevent lower courts from acting without or in excess of jurisdiction, or with grave abuse of discretion, which was evident in the Court of Appeals' reinstatement of the appeal.
Main Doctrine
A replevin suit filed to frustrate the execution of a labor judgment, especially when the vendee is found to be a principal in a scheme to avoid liability, constitutes a subterfuge and is dismissible. The doctrine of the 'law of the case' bars further litigation on issues already passed upon and decided by the Supreme Court.