GR 132453; (February, 2008) (Digest)
G.R. No. 132453 ; February 14, 2008
NATIONAL ELECTRIFICATION ADMINISTRATION (NEA) and NEA MANAGEMENT TEAM, petitioners, vs. HON. FELICIANO V. BUENAVENTURA, DOMINADOR SALUDARES and ANTONIO T. DATU, respondents.
FACTS
The National Electrification Administration (NEA), a government corporation, extended loans to the Nueva Ecija III Electric Cooperative, Inc. (NEECO III) and, due to default, foreclosed on its mortgaged assets. NEA then dissolved NEECO III and created a management team to operate its assets. Meanwhile, former NEECO III employees won an illegal dismissal case against NEECO III and its project supervisor before the Labor Arbiter. A writ of execution was issued to satisfy the monetary award.
NEA filed a third-party claim with the Labor Arbiter, asserting a superior lien over the levied NEECO III properties by virtue of its mortgage and the foreclosure. The Labor Arbiter and the NLRC denied the claim. NEA subsequently filed a petition for certiorari with the Supreme Court (G.R. No. 126571), which was dismissed. The employees then sought execution via the Regional Trial Court (RTC), which granted it. NEA filed the present petition to annul the RTC’s orders, arguing the NLRC had exclusive jurisdiction over execution and that the RTC committed grave abuse of discretion.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion in issuing the writ of execution for the NLRC decision.
RULING
No, the RTC did not commit grave abuse of discretion. The NLRC, a quasi-judicial body, does not have its own sheriff and relies on the sheriff of the regular courts for the execution of its final and executory decisions. This is governed by Article 218 of the Labor Code, which states that the NLRC may deputize the sheriffs of the National Labor Relations Commission or any public official to aid in the execution of its decisions. Established jurisprudence holds that once a labor case becomes final and executory, its execution falls within the jurisdiction of the appropriate RTC, not the NLRC.
NEA’s contention that the RTC had no jurisdiction is therefore untenable. The RTC was acting precisely within its authorized role to assist in the enforcement of a final NLRC judgment. Furthermore, NEA’s claim that it was not subject to the NLRC’s processes is unavailing. By voluntarily participating in the execution proceedings before the labor tribunal—through the filing of its third-party claim and motion to quash—NEA effectively submitted itself to the jurisdiction of the NLRC for the purposes of those proceedings. The petition was correctly denied.