G.R. No. 124711 November 3, 1998
MARICALUM MINING CORP., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (NLRC), SIPALAY MINE FREE LABOR UNION and CECILIO T. SALUDAR, respondents.

FACTS

On August 17, 1984, Labor Arbiter Ethelwoldo Ovejera ordered the reinstatement of illegally dismissed employee Cecilio Saludar against Marinduque Mining and Industrial Corporation. This decision remained unexecuted as Marinduque’s assets were foreclosed by PNB and DBP, and subsequently acquired by petitioner Maricalum Mining Corporation. Eight years later, Saludar moved for a writ of execution against Maricalum. The NLRC, in a 1994 decision, ruled Maricalum was a successor-in-interest liable for Marinduque’s obligations, citing a Deed of Transfer where Maricalum assumed liabilities and its voluntary absorption of Marinduque’s workers. However, the NLRC held the judgment could only be enforced via an action for revival since over five years had lapsed.
Saludar then filed an Action for Revival of Judgment before the NLRC Regional Arbitration Branch. Maricalum moved to dismiss, arguing the labor arbiter lacked jurisdiction over revival actions, which belong to regular courts, and that it was not a party to the original case. The Labor Arbiter denied the motion, ruling the certification of non-forum shopping did not apply to the NLRC and that labor arbiters had jurisdiction over revival actions for labor judgments. The NLRC affirmed, holding that including Maricalum was a necessary incident of execution and that its liability as a successor was already settled in the final 1994 NLRC decision.

ISSUE

Whether the NLRC and its labor arbiters have jurisdiction over an action for revival of a final and executory labor judgment.

RULING

Yes, the NLRC retains jurisdiction over an action for revival of a final labor judgment. The Supreme Court affirmed the NLRC’s decision, rejecting Maricalum’s contention that only regular courts can entertain such actions. The Court clarified that an action for revival of judgment is not an original action but a mere continuation of the original suit for execution. Since the original case involved an illegal dismissal dispute falling under the exclusive jurisdiction of labor tribunals, the NLRC properly exercised jurisdiction over the incident to enforce its final award.
The legal logic is anchored on the principle that a labor tribunal retains control over its final decisions for purposes of execution. Citing Development Bank of the Philippines v. NLRC, the Court held that the NLRC could issue necessary orders for implementing a final award, including impleading a successor corporation like Maricalum as an incident of execution. Furthermore, the Court, referencing Gomez v. Presiding Judge, distinguished that while an “action upon a judgment” can be filed in any competent court, a revival proceeding is a procedural incident of the original case that must be instituted in the court that rendered the judgment. Therefore, as the judgment sought to be revived was rendered by the NLRC in a labor dispute, the revival action was correctly filed there. The Court also upheld the finding of Maricalum’s liability as Marinduque’s successor-in-interest based on the Deed of Transfer and its conduct.