GR L 56833; (July, 1982) (Digest)
G.R. No. L-56833 July 20, 1982
RAMON V. MERANO, petitioner, vs. JUDGE EDUARDO C. TUTAAN, Branch V, Court of First Instance of Quezon City; SAN MIGUEL CORPORATION, ANTONIO TRIA TIRONA, Labor Arbiter, and NATIONAL LABOR RELATIONS COMMISSION, respondents.
FACTS
The National Labor Relations Commission (NLRC) ordered San Miguel Corporation (SMC) to reinstate Ramon V. Merano with backwages. This decision became final and executory after this Court dismissed SMC’s petition for review. Merano received a monetary award but was not reinstated, as SMC opposed it due to his supervening physical unfitness and offered separation pay instead. The NLRC subsequently ruled that due to Merano’s illness, he could no longer be reinstated and was entitled to additional backwages and separation pay.
Prior to that NLRC resolution, Merano filed a special civil action for mandamus in the Court of First Instance (CFI) of Quezon City against SMC and the Labor Arbiter. He sought to compel execution of the NLRC judgment and claimed damages for expected future income, moral damages, attorney’s fees, and medical expenses. The respondent judge dismissed the petition for lack of jurisdiction over the subject matter.
ISSUE
Whether the Court of First Instance has jurisdiction to entertain a mandamus action to compel the execution of a final and executory decision of the National Labor Relations Commission.
RULING
The Supreme Court held that the respondent judge correctly dismissed the petition for mandamus on the ground of lack of jurisdiction. The Court of First Instance is not the proper forum to compel the execution of an NLRC decision or to address the alleged inaction of a Labor Arbiter in enforcing such an award. The NLRC, as a labor tribunal, possesses the inherent authority to execute its final judgments. It is co-equal in rank to the Court of First Instance; therefore, the latter cannot interfere with or assume jurisdiction over the execution process of the NLRC’s final order.
Furthermore, mandamus is an extraordinary writ that is only available when there is no other plain, speedy, and adequate remedy in the ordinary course of law. Merano’s proper recourse was to seek relief from the NLRC itself regarding any delay or refusal in the execution of its decision, not to institute a separate action in the regular courts. The Supreme Court affirmed the order of dismissal, thereby upholding the exclusive jurisdiction of the labor tribunals over the execution of their final and executory decisions.