GR 82278; (May, 1989) (Digest)
G.R. No. 82278 May 12, 1989
EMELINDA SUNGA, ET AL., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, ACD COMPUTER SERVICES and MA. ROSARIO A. CABEL, respondents.
FACTS
Petitioners, former employees, filed a complaint for illegal dismissal and non-payment of benefits against ACD Computer Services and Ma. Rosario Cabel. The labor arbiter ruled in favor of the petitioners, ordering the respondents to pay monetary awards. The decision became final and executory. A writ of execution was issued, leading to the garnishment of a bank account and a levy on properties. Subsequently, the respondents filed a petition for relief from judgment with the NLRC, alleging denial of due process, and obtained a restraining order that stayed the execution. The NLRC later required the respondents to post a bond, but drastically reduced the required amount from over P107,000 to only P5,000. The petitioners moved to dismiss the injunction case, arguing a petition for relief is not a proper remedy under labor rules, but filed the instant petition without awaiting the NLRC’s resolution.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in issuing the resolutions that stayed the execution of a final and partially executed judgment and in entertaining a petition for relief from judgment.
RULING
Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition, setting aside the challenged NLRC resolutions. The Court held that the doctrine of exhaustion of administrative remedies did not bar the petition, as exceptions were present, including unreasonable delay and a patently illegal administrative act that prejudiced the complainants. The labor arbiter’s decision was final and had been partially executed; the NLRC’s actions caused an unreasonable delay in its enforcement.
On the merits, the respondents’ claim of denial of due process was without basis. The records showed they were given ample opportunity to be heard, having been granted extensions to file their position paper, which they ultimately failed to submit. Their petition for relief was a mere last-ditch effort to thwart a final judgment. The NLRC’s initial act of looking into the petition may have been within its discretion, but its subsequent tolerance of the delay and its drastic reduction of the required bond to a nominal sum, which rendered the bond requirement ineffective to secure the award, constituted grave abuse of discretion. The Court directed the NLRC to dismiss the injunction case and to order the full execution of the labor arbiter’s decision without further delay.