A.M. No. RTJ-00-1574. March 28, 2001. GORGONIO S. NOVA, complainant, vs. JUDGE SANCHO DAMES II, Regional Trial Court, Branch 38, Daet, Camarines Norte, respondent.
FACTS

Complainant Gorgonio S. Nova secured a final and executory NLRC decision against R.A. Broadcasting Corporation, Vilma J. Barcelona, and Deo Trinidad for labor claims. To satisfy the judgment, the NLRC sheriff levied on a real property of Vilma J. Barcelona and scheduled a public auction. On June 9, 1998, Vilma J. Barcelona and her husband filed a civil action for damages with a prayer for a temporary restraining order (TRO) in the Regional Trial Court of Daet, Camarines Norte, Branch 38, presided by respondent Judge Sancho Dames II. They argued the property was conjugal and Cesar Barcelona was not a judgment debtor.
On June 15, 1998, respondent Judge issued a TRO, restraining the NLRC sheriff from proceeding with the auction. Complainant Nova subsequently filed this administrative complaint, alleging the issuance constituted gross ignorance of the law. He argued that regular courts lack jurisdiction to interfere with the execution of final labor awards and that Article 254 of the Labor Code prohibits injunctions in labor disputes.

ISSUE

Whether respondent Judge Sancho Dames II is administratively liable for Gross Ignorance of the Law for issuing a temporary restraining order that enjoined the execution of a final NLRC decision.

RULING

Yes, respondent Judge is guilty of Gross Ignorance of the Law. The Supreme Court affirmed the investigating Justice’s recommendation. The legal logic is clear and fundamental: regular courts have no jurisdiction to hear and decide questions incidental to the enforcement of final decisions, orders, or awards rendered by the NLRC and other DOLE tribunals. The execution of such labor judgments is solely within the control of the labor tribunal that issued the writ. Any challenge or controversy relating to its execution must be raised before the labor tribunal itself, not before a regular court.
While the respondent Judge correctly noted that an action for damages for alleged wrongful execution might fall within RTC jurisdiction based on the amount claimed, this separate action cannot be used as a vehicle to obstruct the execution process through ancillary injunctive relief. The issuance of the TRO effectively restrained the execution of a final labor arbiter’s decision, an act beyond the lawful authority of a regional trial court. The prohibition against issuing injunctions in labor cases is a basic and well-settled doctrine intended to prevent precisely this kind of judicial interference. A judge is expected to have mastery of such fundamental legal principles. His failure to recognize this jurisdictional limitation constitutes gross ignorance of the law. Accordingly, the Court imposed a fine of Ten Thousand Pesos (P10,000.00) with a stern warning.