GR 80863; (April, 1989) (Digest)
G.R. No. 80863. April 27, 1989.
ANTONIO M. VILLANUEVA and FULGENCIO B. LAVAREZ, petitioners, vs. HONORABLE ABEDNEGO O. ADRE, Presiding Judge, Regional Trial Court, Branch 22, 11th Judicial Region, and LUCIO VELAYO, respondents.
FACTS
The case originated from labor complaints for unpaid thirteenth-month pay filed against South Cotabato Integrated Port Services, Inc. (SCIPSI) and its president, Lucio Velayo. The National Labor Relations Commission (NLRC) ruled in favor of the workers, and its decision became final. A corporate auditing examiner subsequently determined the liability at P1,134,000.00. Upon the union’s motion, the labor arbiter issued a writ of execution, leading to the levy on two parcels of land registered in Velayo’s name. While a petition questioning the examiner’s computation was pending with the Supreme Court (G.R. Nos. 77300-01), Velayo separately filed a petition with the Regional Trial Court (Special Case No. 227), alleging irregular execution on the grounds that he was not a party to the labor case and that a corporation has a separate juridical personality. The RTC issued a temporary restraining order against the execution.
ISSUE
The primary issue is whether the regular courts have jurisdiction to stay the execution of a final and executory judgment rendered by the labor arbiters and the NLRC.
RULING
The Supreme Court ruled that the regular courts have no jurisdiction to interfere with the execution of a final labor judgment. The Labor Code vests exclusive original jurisdiction over such execution in the Labor Arbiters and the NLRC. The respondent RTC judge therefore committed grave abuse of discretion in assuming jurisdiction over Special Case No. 227 and issuing the restraining order. Any objection by Velayo regarding the execution against his personal properties should have been raised in the ongoing labor proceedings themselves, not in a separate civil action. The filing of the RTC petition while labor proceedings were pending constituted forum-shopping, defined as seeking a favorable opinion in another forum due to an anticipated unfavorable ruling in the original forum. Although the case was rendered moot and academic by a subsequent compromise agreement approved in G.R. Nos. 77300-01, the Court proceeded to rule on the substantive issue to address the ethical violation. Consequently, the Court found respondent Lucio Velayo and his counsel, Atty. Oscar Dinopol, guilty of contempt for forum-shopping, imposing a fine and suspending Atty. Dinopol from the practice of law for three months. The RTC was ordered to dismiss Special Case No. 227.
