G.R. No. L-47796; April 22, 1941
MANILA TRADING & SUPPLY COMPANY, petitioner, vs. PHILIPPINE LABOR UNION, respondent.

FACTS

This case is a sequel to a prior case ( G.R. No. 47653 ) between the same parties. The issues arise from the respondent’s petition for the execution of an order dated March 20, 1940, from the Court of Industrial Relations (CIR) directing the reinstatement of employee Felix Alcantara. After the petitioner filed a petition for a writ of certiorari on the main case, which was given due course by the Supreme Court, the CIR issued an order on September 14, 1940. This order required the petitioner to file a bond sufficient to cover the back wages of Felix Alcantara during the pendency of the case. The petitioner’s motion to set aside this order was denied, prompting the instant appeal by certiorari.

ISSUE

1. Whether the Court of Industrial Relations has the power to order execution of its orders issued under Section 19 of Commonwealth Act No. 103 .
2. Whether the CIR’s order requiring the filing of a bond is null and void for having been issued after the appeal was perfected.
3. Whether the provisions of Section 7, Rule 44 of the new Rules of Court (which state an appeal stays the award unless the Supreme Court directs otherwise) prevail over the provisions of Section 14 of Commonwealth Act No. 103 , as amended by Commonwealth Act No. 559 (which state an appeal does not stay execution unless the CIR orders a stay and may require a bond or deposit).

RULING

1. On the CIR’s power to execute orders under Section 19: The Court rejected the petitioner’s contention that the CIR lacked such power. It held that the CIR’s jurisdiction under Section 19 is incidental to its jurisdiction under Section 4, and therefore, the power to execute its orders under Section 19 is the same as that possessed under Section 4. Denying this power would lead to the absurd result of the CIR having the power to decide a case but not to execute its decision.
2. On the validity of the bond order issued after appeal: The Court held the order was valid. While generally a trial court loses jurisdiction after an appeal is perfected, Section 14 of Commonwealth Act No. 103 , as amended, provides an express statutory exception. It states that an appeal shall not stay execution unless the CIR, for special reasons, orders a stay, in which case it may require a deposit or bond. Thus, the CIR retained the authority to issue the bond order even after the appeal was perfected.
3. On the conflict between the Rules of Court and Commonwealth Act No. 559 : The Court ruled that the specific provisions of Commonwealth Act No. 559 prevail. The new Rules of Court were approved in December 1939 and took effect on July 1, 1940. Commonwealth Act No. 559 was approved and took effect on June 7, 1940. Applying principles of statutory construction, when two acts are inconsistent, the one that takes effect earlier prevails. Since Commonwealth Act No. 559 took effect (June 7, 1940) before the Rules of Court took effect (July 1, 1940), its provisions govern. Furthermore, the legislative intent behind Commonwealth Act No. 559 , which was enacted later than the approval of the Rules, is presumed to repeal the prior rules to the extent of any repugnance (leges posteriores priores contrarias abrogant).
DISPOSITIVE PORTION:
The order of the Court of Industrial Relations is affirmed, with costs against the petitioner.