G.R. No. 184007 ; February 16, 2011
PAQUITO V. ANDO, Petitioner, vs. ANDRESITO Y. CAMPO, ET AL., Respondents.

FACTS

Petitioner Paquito V. Ando was the president of Premier Allied and Contracting Services, Inc. (PACSI), an independent labor contractor. Respondents, hired by PACSI, were dismissed in June 1998 and filed a case for illegal dismissal and money claims. On June 14, 2001, the Labor Arbiter ruled in favor of respondents, directing PACSI and petitioner to pay a monetary award. Petitioner and PACSI appealed to the NLRC, but the NLRC ruled that petitioner failed to perfect his appeal due to non-payment of the supersedeas bond and affirmed the Labor Arbiter’s decision with modification. Upon finality, respondents moved for execution. To answer for the monetary award, the NLRC Acting Sheriff issued a Notice of Sale on Execution of Personal Property over a property covered by TCT No. T-140167 in the name of “Paquito V. Ando married to Erlinda S. Ando.” Petitioner filed an action for prohibition and damages with a prayer for a TRO before the RTC, claiming the property belonged to him and his wife, not to the corporation, and thus could not be subject to execution sale. The RTC denied the prayer for a TRO, holding it had no jurisdiction, as petitioner’s remedy was to file a third-party claim with the NLRC Sheriff, but nonetheless decided the merits. Petitioner did not file a motion for reconsideration but filed a petition for certiorari before the CA. The CA affirmed the RTC’s dismissal on jurisdictional grounds but nullified all other pronouncements. Petitioner’s motion for reconsideration was denied, leading to the present petition.

ISSUE

Whether the Regional Trial Court (and by extension, the Court of Appeals) correctly ruled that it had no jurisdiction over petitioner’s action to restrain the execution of a labor judgment on the ground that the levied property belonged to him personally and his wife, and not to the corporate judgment debtor.

RULING

The Supreme Court found the petition meritorious. It held that the CA correctly upheld the RTC’s lack of jurisdiction to restrain the implementation of the writ of execution issued by the Labor Arbiter. Regular courts have no jurisdiction to hear and decide questions incidental to the enforcement of decisions, orders, or awards rendered in labor cases by appropriate officers and tribunals of the Department of Labor and Employment. The NLRC Manual on the Execution of Judgment governs questions on execution, and the Rules of Court apply only by analogy or suppletorily. The Court ruled that petitioner’s complaint was essentially a third-party claim within the cognizance of the NLRC, as the property subject to execution belonged to petitioner and his wife (the conjugal partnership), making them third parties relative to the Labor Arbiter’s decision against the corporation. Petitioner’s proper remedy was to file a third-party claim with the NLRC Sheriff pursuant to the NLRC Manual, not a separate action in the regular courts. The Court emphasized that to hold otherwise would sanction splitting of jurisdiction, which is obnoxious to the orderly administration of justice.