G.R. No. 118491 ; January 31, 1996
Alfonso Balais, Rogaciano Estonilo, and Alfeo Lotilla, petitioners, vs. Hon. Tirso D’C. Velasco and Central Textile Mills, Inc., respondents.

FACTS

This case originated from a labor dispute between Central Textile Mills, Inc. (CTMI) and its supervisors’ union, resolved by Voluntary Arbitrator Jesus C. Sebastian. He awarded a wage increase to the union. After CTMI’s motion for reconsideration was denied and it failed to fully comply, the Voluntary Arbitrator issued an Alias Writ of Execution. Petitioner Sheriff Alfonso Balais, assisted by Rogaciano Estonilo, levied upon specific personal properties of CTMI—described as various lots of scrap metals, junked machineries, and unserviceable weaving machines—and conducted an auction sale. Petitioner Alfeo Lotilla was the winning bidder, a Certificate of Sale was issued, and the properties were released to him.
CTMI then filed a civil case for damages with the Regional Trial Court (RTC), alleging that during the execution, petitioners and union members, with police assistance, unlawfully dismantled and hauled away not just the levied scrap but also serviceable machinery permanently installed on concrete platforms. The RTC issued a temporary restraining order. Petitioners moved to dismiss the RTC case, arguing lack of jurisdiction, as any question on the execution of a labor arbiter’s award falls under the exclusive jurisdiction of the National Labor Relations Commission (NLRC) or the originating voluntary arbitrator.

ISSUE

Whether the Regional Trial Court has jurisdiction over CTMI’s action for damages arising from the alleged irregularities in the implementation of the Alias Writ of Execution issued by a voluntary arbitrator.

RULING

No. The Supreme Court granted the petition, ruling that the RTC has no jurisdiction. The legal logic is anchored on the doctrine that the court or tribunal which issued a writ of execution retains jurisdiction to determine all questions arising from its implementation, including allegations of excesses by the executing officers. The Alias Writ of Execution originated from the Voluntary Arbitrator in a labor dispute. Consequently, any incident relating to its enforcement, such as claims that the sheriffs exceeded their authority by levying on properties not included in the writ or by dismantling permanent machinery, is incidental to the execution of a labor award.
Such matters must be litigated before the Voluntary Arbitrator himself, pursuant to his inherent power to control and correct the processes of his own tribunal. To allow the RTC to adjudicate these issues would sanction split jurisdiction, which is detrimental to the orderly administration of justice. Regular courts are devoid of jurisdiction to hear incidents incidental to the enforcement of decisions, orders, or awards rendered by labor tribunals. Therefore, the RTC was permanently enjoined from proceeding with the civil case for damages.