Villaflores v. Ram System Services, Inc.
REITERATIONFacts
The Antecedents: Petitioner Mario Danilo Villaflores and his wife, Avelita Villaflores, filed separate complaints against RAM System Services, Inc. (RSSI) and its President, Rogelio U. Yap, for illegal dismissal and monetary benefits. Mario claimed to be employed as a computer coordinator from November 2, 1992, with a monthly salary of P20,000.00, while Avelita alleged employment as a computer instructor from June 1, 1994, with a monthly salary of P6,500.00. Their services were terminated on June 9, 1997. Respondents, however, contended that Mario was not an employee but rather a treasurer and incorporator of RSSI. They also asserted that Avelita was not rehired for the subsequent school year. A dispute arose concerning funds from an agreement with Our Lady of Perpetual Succor College, leading Mario to accuse Yap of financial irregularities and demand inspection of corporate records, which resulted in a separate case filed with the Securities and Exchange Commission. Procedural History: The Labor Arbiter initially dismissed both complaints on October 14, 1998, ruling that the complainants were not employees of RSSI. This decision was affirmed by the National Labor Relations Commission (NLRC) on October 29, 1999, and a subsequent motion for reconsideration was denied. The spouses Villaflores then filed a petition for certiorari with the Court of Appeals (CA), which, on March 28, 2001, reversed the NLRC's decision, declaring the termination of both Mario and Avelita illegal and ordering their reinstatement or payment of separation pay, along with backwages. This CA decision became final and executory. Subsequently, during the enforcement proceedings before the Labor Arbiter, a dispute arose over the computation of Mario's monetary award, particularly his monthly salary. The Labor Arbiter, affirming the NLRC's Research and Computation Unit's calculation based on P20,000.00 monthly salary, issued an order. The NLRC dismissed the respondents' appeal, and their subsequent motion for reconsideration was also denied. Respondents then filed another petition for certiorari with the CA, which, on August 31, 2004, reversed the NLRC resolutions and remanded the case for recomputation of Mario's award based on P6,500.00, similar to his wife's salary. The Petition: Petitioner Mario Danilo Villaflores filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the August 31, 2004 Decision of the Court of Appeals in CA-G.R. SP No. 84941. Petitioner argues that the CA erred in setting aside the NLRC's finding, which he contends was supported by substantial evidence. He asserts that the CA gravely abused its discretion in granting the respondents' petition for certiorari, as the NLRC's computation was based on the evidence, including paychecks and vouchers, and that the dispositive portion of the original CA decision, while not specifying the amount, referred to findings of fact supported by evidence. Petitioner further argues that respondents were not denied due process, as they had the opportunity to comment on the computation and even questioned aspects of it. The core of petitioner's argument is that the CA should not have interfered with the execution of the prior, final and executory decision of another division of the CA (the Sixteenth Division in CA-G.R. SP No. 58836), as only that division retained jurisdiction over the enforcement proceedings. He contends that the Ninth Division of the CA lacked jurisdiction to pass upon issues related to the execution of the Sixteenth Division's judgment.
Issue(s)
Whether the Ninth Division of the Court of Appeals had jurisdiction to entertain the petition for certiorari assailing the execution proceedings of a decision rendered by the Sixteenth Division of the same appellate court. Whether the monetary award for Mario Danilo Villaflores should be based on a P20,000.00 monthly salary or P6,500.00.
Ruling
The petition is granted. The Decision and Resolution of the Ninth Division of the Court of Appeals in CA-G.R. SP No. 84941 are set aside and nullified. The case is remanded to the Sixteenth Division of the Court of Appeals for clarification regarding the monthly salary of petitioner Mario Danilo Villaflores.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the Sixteenth Division of the Court of Appeals, which rendered the decision in CA-G.R. SP No. 58836 that had become final and executory, retained exclusive jurisdiction over the case for its enforcement. The Labor Arbiter, in executing the decision, was under the control and supervision of the Sixteenth Division. Therefore, the Ninth Division of the Court of Appeals committed a grave error in entertaining the petition for certiorari filed by respondents in CA-G.R. SP No. 84941. The various divisions of the Court of Appeals are coordinate courts, and one division should not interfere with the proceedings of another division to avoid confusion and ensure the orderly administration of justice. The proper recourse for the respondents would have been to file a motion for clarification before the Sixteenth Division of the CA in CA-G.R. SP No. 58836, not to file a separate petition for certiorari with another division. On the computation of the monetary award: The Supreme Court did not definitively rule on the correct monthly salary for Mario Danilo Villaflores. Instead, it held that the Ninth Division of the CA erred in delving into the merits of the computation. The Court noted that the dispositive portion or the body of the decision in CA-G.R. SP No. 58836 did not explicitly state that Mario's monthly salary was P20,000.00 at the time of his termination. Consequently, the issue of the exact monthly salary and the corresponding monetary award should be clarified by the Sixteenth Division of the CA, which has exclusive jurisdiction over the enforcement of its own decision. The Court emphasized that the Ninth Division arrogated unto itself the jurisdiction vested solely in the Sixteenth Division by reviewing the computation and the evidence presented.
Main Doctrine
A division of the Court of Appeals should not interfere with the enforcement of a decision rendered by another division of the same court, as the division that rendered the decision retains exclusive jurisdiction over its execution.