Deltaventures Resources, Inc. v. Cabato
REITERATIONFacts
The Antecedents: A Decision was rendered by Executive Labor Arbiter Norma Olegario in NLRC Case No. 01-08-0165-89, finding Green Mountain Farm, Roberto Ongpin, and Almus Alabe guilty of Illegal Dismissal and Unfair Labor Practice, ordering them to pay monetary awards and exemplary damages to the complainants (Alejandro Bernardino, et al.). Procedural History: After the respondents' appeals were denied, a writ of execution was issued by Executive Labor Arbiter Gelacio C. Rivera, Jr. The sheriff levied upon personal properties and subsequently a real property registered in the name of Roberto Ongpin. The public auction was scheduled. The Petition: Petitioner Deltaventures Resources, Inc. filed a third-party claim with the Commission, asserting ownership over the levied property. The Labor Arbiter suspended the auction. Subsequently, petitioner filed a complaint for injunction and damages with the Regional Trial Court (RTC) of La Trinidad, Benguet, reiterating its ownership claim. The RTC issued a temporary restraining order. Petitioner later amended its complaint to implead the Labor Arbiter and the private respondent-laborers. The private respondents moved to dismiss the civil case for lack of jurisdiction. The RTC dismissed petitioner's amended third-party complaint, holding that it had no jurisdiction to issue an injunction against the execution of an NLRC decision, that the NLRC retains authority over execution proceedings, and that petitioner, by filing a third-party claim with the Commission, engaged in forum shopping. The motion for reconsideration was denied, leading to the filing of the present special civil action for certiorari.
Issue(s)
Whether the Regional Trial Court (RTC) erred in dismissing petitioner's amended third-party complaint on the ground of lack of jurisdiction. Whether the RTC has the authority to issue an injunction or restraining order to enjoin the execution of a decision rendered by the National Labor Relations Commission (NLRC). Whether the third-party claim filed by petitioner is an incident of the labor case and thus falls within the exclusive jurisdiction of the NLRC.
Ruling
The petition is denied. The assailed Orders of respondent Judge Fernando P. Cabato dated November 7, 1994, and December 14, 1994, are affirmed. The records are remanded to the National Labor Relations Commission for further proceedings.
Ratio Decidendi
On the jurisdiction of the RTC to issue an injunction against an NLRC decision: The Court reiterated the hornbook principle that jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint. In this case, the petitioner filed a third-party claim before the RTC due to a writ of execution issued by the NLRC Sheriff against a property it claims ownership of. While ostensibly for recovery of possession and injunction, the complaint in essence challenged the legality of the levy and the acts of the Labor Arbiter and Sheriff in implementing the writ. This challenge was an incident of the labor case, which falls under the exclusive jurisdiction of the Labor Arbiter and the NLRC. Therefore, the RTC, being a co-equal body of the NLRC, has no jurisdiction to issue an injunction or restraining order to enjoin the execution of any decision of the latter. The broad powers granted to the Labor Arbiter and the NLRC by the Labor Code vest in them exclusive jurisdiction over incidents arising from, in connection with, or relating to labor disputes. On the nature of the third-party claim and the NLRC's authority: The Court found that the petitioner failed to realize that by filing its third-party claim with the deputy sheriff, it submitted itself to the jurisdiction of the Commission acting through the Labor Arbiter. The petitioner was controverting the decision of the Labor Arbiter, not merely the act of the deputy sheriff in executing the order. Jurisdiction, once acquired, is not lost. Any irregularities in the issuance and execution of the writ of execution should be referred to the same administrative tribunal which rendered the decision, as it has the inherent power to correct errors of its ministerial officers and control its own processes. The Labor Code, specifically Article 254, explicitly prohibits the issuance of injunctions or restraining orders in cases involving or growing out of labor disputes by any court or other entity, except as otherwise provided. The issues raised by the petitioner were interwoven with the execution of the Commission's decision, making Article 254 applicable. On the proper procedure for third-party claims: The Court emphasized that the petitioner should have filed its third-party claim before the Labor Arbiter, from whom the writ of execution originated, before instituting the civil case. The NLRC's Manual on Execution of Judgment provides the mechanism for a third-party claimant to assert their claim over a property levied upon by the sheriff. The power of the Labor Arbiter to issue a writ of execution carries with it the power to inquire into the correctness of the execution of his decision and to consider supervening events during execution. The RTC's dismissal of the third-party complaint was therefore proper, upholding the principle that regular courts cannot interfere with the execution of labor decisions.
Main Doctrine
A Regional Trial Court has no jurisdiction to issue an injunction or restraining order to enjoin the execution of a decision of the National Labor Relations Commission (NLRC), as both are considered co-equal bodies, and matters arising from or connected with labor disputes fall under the exclusive jurisdiction of the NLRC.