G.R. No. 118216 ; March 9, 2000
DELTAVENTURES RESOURCES, INC., petitioner, vs. HON. FERNANDO P. CABATO, Presiding Judge Regional Trial Court, La Trinidad, Benguet, Branch 62; HON. GELACIO L. RIVERA, JR., Executive Labor Arbiter, NLRC-CAR, Baguio City, ADAM P. VENTURA, Deputy-Sheriff, NLRC-CAR, Baguio City; ALEJANDRO BERNARDINO, et al., respondents.

FACTS

A final and executory NLRC decision ordered respondents Green Mountain Farm, Roberto Ongpin, and Almus Alabe to pay monetary awards to the private respondent-laborers for illegal dismissal. To satisfy the judgment, NLRC Deputy Sheriff Adam Ventura levied upon a real property registered in the name of Roberto Ongpin. Prior to the scheduled auction sale, petitioner Deltaventures Resources, Inc. filed a third-party claim with the NLRC, asserting ownership over the levied property. The Labor Arbiter suspended the auction to resolve the claim.
Subsequently, petitioner filed a complaint for injunction and damages with the Regional Trial Court (RTC) of La Trinidad, Benguet, seeking to enjoin the sheriff from proceeding with the execution sale based on the same ownership claim. The RTC issued a temporary restraining order. The private respondent-laborers moved to dismiss the civil case for lack of jurisdiction.

ISSUE

Whether the Regional Trial Court has jurisdiction to take cognizance of a complaint for injunction filed by a third-party claimant seeking to enjoin the execution of a final and executory NLRC decision.

RULING

No, the RTC has no jurisdiction. The Supreme Court affirmed the RTC’s dismissal of the complaint. The legal logic is anchored on the doctrine of non-interference and the exclusive jurisdiction of the NLRC over execution proceedings. A Regional Trial Court, being a co-equal body of the National Labor Relations Commission, has no authority to issue any injunction or restraining order to enjoin the execution of the NLRC’s final decision. Such an act would constitute an impermissible interference with a co-equal and independent quasi-judicial agency.
The power to execute its judgments carries with it the NLRC’s inherent authority to determine all questions arising from such execution, including third-party claims over levied properties. The proper remedy for petitioner was to pursue its claim within the NLRC’s own execution proceedings, as provided under its rules, and not to seek injunctive relief from the regular courts. By initially filing its third-party claim with the NLRC, petitioner invoked that body’s jurisdiction and was bound to await its resolution. The filing of the separate civil action in the RTC constituted forum shopping. The execution of labor decisions, being a continuation of the main labor case, remains within the exclusive ambit of the NLRC’s jurisdiction.