Far East Realty Investment, Inc. v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a labor case where Ricardo Granada was ordered reinstated by the Court of Industrial Relations (CIR) with backwages. This decision was affirmed by the Supreme Court. Subsequently, Granada filed a separate claim for wage differentials and holiday pay, alleging he was receiving less than the minimum wage and was entitled to extra pay for Sundays and holidays. 2. Procedural History: In Case No. 3920-ULP, the CIR ordered Granada's reinstatement and backpay, which was affirmed by the Supreme Court. A writ of execution was issued, and petitioners paid Granada backwages and a compromise amount. Later, in Case No. 2330-V, the CIR ordered petitioners to pay Granada P3,642.00 for wage differentials and holiday pay. Petitioners appealed this order to the Supreme Court, but the appeal was denied for being filed out of time. A writ of execution was issued for the P3,642.00, and petitioners' motion to quash and motion for reconsideration were denied by the CIR. 3. The Petition: This is a petition for review under Rule 45 of the Rules of Court, seeking to annul the CIR's orders denying the motion to quash execution and the motion for reconsideration. Petitioners argue that the CIR acted without or in excess of jurisdiction by resurrecting a terminated case, that the order for wage differential pay contradicted a prior order, and that the court lacked jurisdiction to issue the writ of execution due to issues with employer-employee relationship, reinstatement claims, and the nature of the wage demand. The Supreme Court found these arguments to be grounds for appeal, not for quashing an execution of a final and executory judgment.
Issue(s)
Whether the CIR acted without or in excess of jurisdiction or with grave abuse of discretion in issuing the questioned orders. Whether Case No. 2330-V could be resurrected by a case already closed and terminated, and whether the order in Case No. 2330-V contravened the order in Case No. 3920-ULP. Whether the CIR had jurisdiction to issue the writ of execution based on a judgment it allegedly had no jurisdiction to render.
Ruling
The petition is untenable and is hereby dismissed. Petitioners are ordered to pay respondent Ricardo Granada the sum of P3,642.00 with interest at 12% per annum from October 10, 1973, until fully paid. The decision is immediately executory.
Ratio Decidendi
On the propriety of the writ of execution and the CIR's jurisdiction: The Court held that the order of the CIR dated February 15, 1971, which was the basis for the writ of execution, had long become final and executory. Petitioners' appeal of this order was denied by the Supreme Court for having been filed out of time. Therefore, the CIR could not be faulted for issuing the writ of execution, as its duty in such a situation is ministerial. The Court reiterated the fundamental rule that a court cannot refuse to issue a writ of execution upon a final and executory judgment. The exceptions to this rule, such as supervening events rendering execution unjust, or the order of execution varying the terms of the judgment, were found to be absent in this case. Consequently, the general rule that an order of execution of a final and executory judgment is not appealable applies. On Case No. 2330-V and Case No. 3920-ULP: The Court found that Case No. 3920-ULP and Case No. 2330-V were founded on different causes of action, negating the claim that one case was resurrecting the other or that there was a contravention of orders between them. On the grounds for quashing execution and the alleged lack of jurisdiction: The Court found that the grounds raised by petitioners, such as the alleged lack of employer-employee relationship, private respondent not seeking reinstatement, the nature of the demand for differential pay, and the wage claim not being above the statutory minimum, were not proper grounds for a motion to quash execution. These arguments were suitable for an appeal, a remedy that petitioners had already attempted and failed to pursue successfully due to their failure to file the appeal on time.
Main Doctrine
A court cannot refuse to issue a writ of execution upon a final and executory judgment, as its duty is ministerial, except in specific instances where execution would be unjust due to supervening events, or if the order of execution varies the terms of the judgment.