G.R. No. 94810 . March 18, 1992. EASTERN METROPOLITAN BUS CORP., RUBEN TY and GEORGE UY, petitioners, vs. HON. EDILBERTO PANGAN, and ABE ESTRADA, in their capacities as Labor Arbiter and Deputy Sheriff, respectively, of the NLRC, KATIPUNAN NG MGA MANGGAGAWANG PILIPINO and EVARISTO DOROIN, respondents.
FACTS

Petitioners sought to annul a writ of execution issued by Labor Arbiter Edilberto Pangan in a labor case ordering EMBC to pay monetary awards to twenty employees. The computation of the award by the NLRC’s Research Unit amounted to P284,221.00, but this failed to account for payments already made by EMBC to fifteen claimants who had executed releases and quitclaims. Based on this flawed computation, a writ was issued. NLRC Sheriff Abe Estrada levied four EMBC buses and scheduled their auction. Despite EMBC’s timely filing of an urgent motion to quash the writ and for recomputation, Labor Arbiter Pangan ignored it and directed the sale to proceed. The buses were sold for only P150,000 to respondent Evaristo Doroin. Pangan approved the sale and ordered the buses’ release to Doroin, which was swiftly implemented.
EMBC petitioned the Supreme Court for certiorari and prohibition. The Court issued a Temporary Restraining Order and a Writ of Preliminary Mandatory Injunction, directing the return of the buses to EMBC upon posting a bond. Doroin opposed, falsely claiming the buses were dilapidated and had already been disposed of to third parties. The Solicitor General, in a Manifestation, found grave abuse of discretion by Pangan and Estrada, highlighting the failure to hear the motion for recomputation and to allow payment before levy.

ISSUE

Whether public respondents committed grave abuse of discretion in issuing and implementing the writ of execution, and whether respondents are liable for contempt.

RULING

Yes. The Supreme Court found grave abuse of discretion amounting to lack or excess of jurisdiction. The legal logic is anchored on the fundamental requirement of due process in execution proceedings. Labor Arbiter Pangan acted with manifest partiality and capriciousness by disregarding EMBC’s urgent motion for recomputation, which raised a valid claim of partial satisfaction of the judgment through payments evidenced by quitclaims and vouchers. Execution must strictly conform to the judgment debtor’s actual obligation; a writ based on a grossly inflated computation, ignoring legitimate payments, is void. Sheriff Estrada compounded the abuse by conducting a hasty sale at a grossly inadequate price without affording the debtor a reasonable opportunity to satisfy the judgment, violating rules on execution sales.
Furthermore, respondents were found guilty of contempt for willfully disobeying the Court’s lawful order to return the buses. Doroin’s false testimony under oath that the buses had been scrapped constituted perjury. The Court annulled the writ of execution, the auction sale, and the award of the buses to Doroin, confirming their return to EMBC. It ordered the NLRC to recompute the award accurately. As disciplinary sanctions, the Court fined and imposed imprisonment on Estrada and Doroin for contempt, directed the filing of a perjury charge against Doroin, and suspended Labor Arbiter Pangan from the practice of law for one year for serious misconduct.