GR L 78223; (December, 1988) (Digest)
G.R. No. L-78223 and G.R. No. L-79403, December 19, 1988
HEIRS OF FRANCISCO GUBALLA, SR. and GUBALLA MARKETING CORPORATION, petitioners, vs. THE COURT OF APPEALS and SPOUSES RUFINO B. RISMA and TECLA GOTICO-RISMA, respondents. EMETERIO M. MOZAR, petitioner, vs. THE COURT OF APPEALS, HON. ERNESTO MADAMBA, CITY SHERIFF OF MANILA and HEIRS OF FRANCISCO GUBALLA, SR., respondents.
FACTS
In G.R. No. 78223 , the property of Francisco Guballa, Sr. was levied and sold at public auction to satisfy a labor judgment in favor of BUSCOPE Labor Union. BUSCOPE’s president later sold the property to Atty. Rufino Risma. However, the Deputy Minister of Labor subsequently set aside the auction sale, declaring Guballa’s obligation fully satisfied and restoring ownership to him. Despite this nullification, the Risma spouses filed an action for a writ of possession in the Court of First Instance (CFI). Guballa moved to dismiss, arguing the CFI lacked jurisdiction as the matter arose from a labor case under the exclusive jurisdiction of the National Labor Relations Commission (NLRC). The CFI denied the motion and later granted the writ. Guballa appealed to the Court of Appeals, which dismissed the appeal for procedural reasons.
In the related G.R. No. 79403 , Emeterio Mozar, a lessee of the property from Atty. Risma, became involved in an ejectment case filed by Guballa. The Metropolitan Trial Court (MTC) ruled in favor of Guballa, a decision affirmed by the Regional Trial Court (RTC). Mozar’s petition for certiorari in the Court of Appeals was dismissed. He then elevated the matter to the Supreme Court.
ISSUE
The core issues were whether the CFI had jurisdiction over the action for a writ of possession arising from a voided execution sale in a labor case, and whether Mozar’s petition had been rendered moot.
RULING
The Supreme Court ruled in favor of the Guballa heirs in G.R. No. 78223 and dismissed Mozar’s petition in G.R. No. 79403 . The Court held that the CFI had no jurisdiction over the action for a writ of possession. The case originated from the execution of a labor decision, and the authority to resolve all incidents arising from such execution, including the issuance of a writ of possession after the sale was annulled, remained vested in the NLRC. The Labor Code granted the NLRC exclusive appellate jurisdiction over cases arising from employer-employee relations, and this encompassed incidents related to the enforcement of its judgments. Therefore, the CFI should have dismissed the case for lack of jurisdiction. The Court of Appeals’ dismissal of Guballa’s appeal on procedural grounds was reversed, and the CFI case was ordered dismissed.
Regarding G.R. No. 79403 , the Supreme Court found the petition moot and academic. The ejectment judgment in favor of Guballa had long become final and executory, and possession of the property had already been restored to him. The Court strongly censured Mozar and his counsel for filing multiple and repetitious petitions that abused court processes, delayed execution, and exhibited a lack of candor. Treble costs were assessed against Mozar, to be paid by his counsel personally.