Guimoc v. Rosales
REITERATIONFacts
The Antecedents: The underlying dispute originated from a labor case, NLRC Case No. RAB-VIII-2-00064-88, wherein Romeo M. Cruz, et al. sued Looc Bay Timber Industries, Inc. (LBTI) and Visayan Forest Development Corp. (VFDC) for non-payment of wages, minimum wage, Ecola, 13th month pay, and service incentive leave pay. A decision was rendered on October 26, 1988, ordering the respondents to pay the complainants a total sum of P2,421,996.80, subject to deductions for any advance or partial payments made. Procedural History: Following the decision, Labor Arbiter Benjamin Guimoc issued a writ of execution on January 4, 1989, directing Sheriff Felicisimo Basilio to enforce the judgment. Sheriff Basilio levied on the movable and immovable properties of LBTI. On February 3, 1989, General Insurance Services Corporation (GESCOR) filed a third-party claim asserting ownership over some of the levied properties. Labor Arbiter Guimoc, after conducting hearings, issued a resolution on April 24, 1989, dismissing the third-party claims, including that of GESCOR. Subsequently, GESCOR filed a petition for Prohibition, Certiorari, Annulment of Judgment, and Quashal of Levy with Preliminary Prohibitory Injunction against Guimoc and Basilio before the Regional Trial Court (RTC) of Allen, Samar, docketed as Spl. Civil Action A-47. On June 2, 1989, the RTC issued a restraining order enjoining the sale of the properties. The petitioners, Guimoc and Basilio, filed a motion to dismiss the RTC case on jurisdictional grounds, which was denied by the RTC on June 28, 1989. The Petition: Petitioners Benjamin Guimoc and Felicisimo Basilio, in their capacities as Labor Arbiter and Sheriff of the NLRC respectively, filed this petition for certiorari, prohibition, and mandamus with the Supreme Court. They seek to annul the orders of the respondent RTC Judge Clemente C. Rosales dated June 2, 1989 (restraining order) and June 28, 1989 (denial of motion to dismiss). The petitioners argue that the RTC lacked jurisdiction to interfere with the execution of a final and executory judgment of the NLRC, citing Article 254 of the Labor Code which prohibits injunctions in labor disputes. They contend that GESCOR should have appealed the dismissal of its third-party claim to the NLRC, as appellate jurisdiction over such matters rests exclusively with the NLRC, not the regular courts.
Issue(s)
Whether the Regional Trial Court has jurisdiction to issue an injunction to stop the execution of a final and executory judgment of the National Labor Relations Commission. Whether the denial of the third-party claim by the Labor Arbiter, without an appeal to the NLRC, renders the denial final and unappealable to the civil courts.
Ruling
The petition is granted. The assailed orders of the respondent RTC Judge are annulled and set aside. The Writ of Execution dated January 4, 1989, is ordered to be enforced and implemented.
Ratio Decidendi
On the jurisdiction of the RTC to interfere with NLRC execution: The Supreme Court held that a civil court cannot interfere by injunction with the execution of a final and executory judgment of the NLRC. Article 254 of the Labor Code explicitly prohibits the issuance of any temporary or permanent injunction or restraining order in any case involving or growing out of labor disputes, except as otherwise provided in Articles 218 and 264 of the Code. The execution of NLRC judgments falls under the exclusive jurisdiction of the NLRC and its sheriffs, who are guided by the Sheriffs Manual. The RTC, by issuing the restraining order and denying the motion to dismiss, acted without jurisdiction. On the finality of the denial of the third-party claim: The Supreme Court ruled that upon denial of its third-party claim by Labor Arbiter Guimoc, GESCOR should have appealed to the NLRC within ten (10) working days, as prescribed by Section 2, Rule VI of the Manual of Instructions for Sheriffs of the NLRC. Instead, GESCOR filed a petition in the RTC. Appellate jurisdiction over decisions, awards, and orders of the Labor Arbiters is exclusively vested in the NLRC. Since GESCOR failed to seasonably appeal the resolution denying its third-party claim to the NLRC, that resolution became final. Consequently, the RTC had no jurisdiction to review the Labor Arbiter's orders denying the third-party claim. Jurisdiction, once acquired by an administrative tribunal, is not lost upon the instance of the parties but continues until the case is terminated.
Main Doctrine
A civil court cannot issue an injunction to interfere with the execution of a final and executory judgment of the National Labor Relations Commission (NLRC).