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. 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 because they were not furnished a copy of the complainants’ position paper and that their appeal was delayed due to a misplaced decision. The NLRC issued resolutions that effectively stayed the execution, including an order requiring a bond, which was later drastically reduced, thereby delaying the full enforcement of the final judgment.
The petitioners moved to dismiss the petition for relief, arguing it is not a remedy under the Labor Code, but filed the instant petition for certiorari without awaiting the NLRC’s resolution. They seek to annul the NLRC’s resolutions, prohibit further proceedings in the injunction case, and compel the full execution of the labor arbiter’s final decision.
ISSUE
Whether the NLRC committed grave abuse of discretion in issuing the resolutions that stayed the execution of a final and partially executed judgment based on a petition for relief from judgment.
RULING
Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition, directing the dismissal of the injunction case and the full execution of the labor arbiter’s decision. The Court held that the doctrine of exhaustion of administrative remedies, which the Solicitor General invoked, yields to exceptions present here: unreasonable delay and a purely legal question. The NLRC’s inaction on the challenge to the petition for relief for almost a year, while the final judgment remained partially unexecuted, constituted an unreasonable delay prejudicial to the workers.
On the merits, the respondents’ claim of denial of due process was unfounded. The records showed they were granted multiple extensions and postponements to file their position paper but failed to do so or to attend hearings. Their only actions were dilatory motions. Their claim of not receiving the complainants’ position paper was irrelevant as they forfeited their right to respond by their inaction. The petition for relief was a mere last-ditch effort to thwart a final and executory judgment, which had already been partially implemented through garnishment. The NLRC’s initial act of looking into the case may have been correct, but its tolerance of the protracted delay in enforcing a final judgment constituted reversible error, warranting the Court’s exercise of its certiorari powers to correct such grave abuse of discretion.