Filipino Pipe Workers Union v. Batario
REITERATIONFacts
1. The Antecedents: A labor dispute arose in 1981 between Filipino Pipe and Foundry Corporation (COMPANY) and the Filipino Pipe Workers Union (Union) due to a deadlock in collective bargaining negotiations concerning vacation and sick leaves, wage increases, and retirement gratuity. The dispute was certified for compulsory arbitration, and a Labor Arbiter issued a decision ordering the parties to conclude a collective bargaining agreement, including specific provisions for commutable vacation and sick leave benefits and a P1.00 across-the-board annual increase. 2. Procedural History: The COMPANY appealed the Labor Arbiter's decision to the National Labor Relations Commission (NLRC), but the appeal was dismissed for being filed out of time. Subsequent petitions for certiorari by the COMPANY to the Supreme Court (G.R. No. 64074 and G.R. No. 70480) were also dismissed. The Union then sought execution of the Labor Arbiter's decision. To prevent execution, the COMPANY filed a petition for prohibition with preliminary injunction with the Regional Trial Court (RTC) of Pasig, seeking to annul the Labor Arbiter's judgment. The RTC, presided over by Judge Batario, Jr., denied the Union's motion to dismiss, asserting jurisdiction. Separately, the NLRC, after setting aside a prior order and writ of execution, directed the computation of the award, including a P3.00 daily increase. The COMPANY's petition to the NLRC to hold action pending the RTC case was dismissed, leading to another petition for certiorari by the COMPANY to the Supreme Court (G.R. No. 79417). 3. The Petition: The Filipino Pipe Workers Union filed a petition for certiorari (G.R. No. 75851) challenging the RTC's assumption of jurisdiction over Civil Case No. 53236, arguing that the RTC lacked jurisdiction to annul a labor arbiter's decision. The COMPANY filed a separate petition for certiorari (G.R. No. 79417) assailing the NLRC's resolution directing the inclusion of a P3.00 daily increase in the computation of the award. The Supreme Court consolidated both petitions. The Court granted the Union's petition in G.R. No. 75851, declaring the RTC proceedings null and void for lack of jurisdiction, and dismissed the COMPANY's petition in G.R. No. 79417, affirming the NLRC's directive to include statutory wage increases in the final award, noting the COMPANY's failure to seek exemption from relevant wage orders.
Issue(s)
Whether the Regional Trial Court has jurisdiction to annul a decision of a Labor Arbiter and restrain its execution. Whether the P3.00 daily wage increase should be included in the computation of the final award.
Ruling
The Supreme Court granted the petition in G.R. No. 75851, declared Civil Case No. 53236 of the RTC null and void for lack of jurisdiction, and dismissed the petition in G.R. No. 79417 for lack of merit and mootness. The NLRC was directed to proceed with the computation of the final award, including statutory wage increases.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court: The Court held that the allegations in the COMPANY's complaint before the RTC did not constitute grounds for annulment of judgment. The claims that the Labor Arbiter's decision was without basis in fact and law, violated due process, exceeded jurisdiction, or was void ab initio, were matters that should have been raised on appeal to the NLRC and subsequently through certiorari proceedings to the Supreme Court. The RTC's assertion of jurisdiction over Civil Case No. 53236 was found to be untenable because appellate jurisdiction over labor arbiters' decisions is exclusively vested in the NLRC. The Court emphasized that the COMPANY had lost its opportunity to appeal due to its own negligence and could not regain a lost remedy under the guise of an annulment action. The Court also noted that the COMPANY's petition to the RTC deliberately omitted reference to prior Supreme Court certiorari proceedings, constituting a "clever ruse" to mislead the RTC. The Court reiterated that labor disputes are generally outside the purview of injunctions or restraining orders from regular courts, as provided by Article 254 of the Labor Code. On the inclusion of the P3.00 daily wage increase: The Court affirmed the NLRC's resolution to include the P3.00 daily increase in the computation of the award. The Solicitor General clarified that this increase was made pursuant to Wage Orders Nos. 2 and 3, which took effect after the Labor Arbiter's decision became final but pending its execution. The Court interpreted the provisions of Wage Orders Nos. 2, 3, 5, and 6 to mean that statutory wage increases are separate from those in collective bargaining agreements and must be integrated into the salary scale to attain the decreed rates. The Court noted that the COMPANY had not sought exemption from Wage Orders Nos. 2 and 3, and its exemptions from Wage Orders Nos. 5 and 6 had expired by the time the NLRC resolution was issued. Therefore, integrating the statutory wage increases was the proper recourse for full compliance with the law, and the NLRC committed no grave abuse of discretion in ordering its inclusion.
Main Doctrine
Regional Trial Courts do not have jurisdiction to annul decisions of Labor Arbiters or the NLRC, as such actions are proper subjects of appeal to the NLRC and subsequent certiorari proceedings before the Supreme Court. Actions seeking to annul labor arbiter decisions based on alleged errors in fact or law, or excess of jurisdiction during the exercise of authority, are not grounds for annulment of judgment but for appeal.