G.R. No. L-75851 and G.R. No. 79417, July 29, 1988
Filipino Pipe Workers Union (NLU) vs. Judge Demetrio M. Batario Jr., et al. and Filipino Pipe and Foundry Corporation vs. National Labor Relations Commission, et al.

FACTS

A labor dispute between Filipino Pipe and Foundry Corporation (the Company) and the Filipino Pipe Workers Union (the Union) over collective bargaining negotiations was certified for compulsory arbitration. On March 19, 1981, Labor Arbiter Cornelio Linsangan rendered a decision, ordering the parties to conclude a collective bargaining agreement with specific benefits, including a P1.00 across-the-board annual wage increase. The Company’s appeal to the NLRC was dismissed for being filed out of time, and the Supreme Court subsequently dismissed the Company’s petition for certiorari (G.R. No. 64074) in 1983, making the Labor Arbiter’s decision final and executory.
To prevent execution, the Company filed a petition for prohibition with the Regional Trial Court of Pasig (Branch 158, presided by Judge Batario Jr.) in 1986, seeking to annul the 1981 labor decision and restrain its execution. The RTC denied the Union’s motion to dismiss, asserting jurisdiction under BP 129, reasoning that an action for annulment of judgment is incapable of pecuniary estimation. Meanwhile, the Labor Arbiter issued a writ of execution in April 1986, which the NLRC initially set aside but later, in an April 28, 1987 resolution, ordered the computation of the final award, including a P3.00 daily wage increase from subsequent wage orders. The Company protested, citing the pending RTC case.

ISSUE

The primary issue is whether the Regional Trial Court has jurisdiction over the Company’s action to annul the final and executory decision of the Labor Arbiter. A secondary issue is whether the NLRC committed grave abuse of discretion in ordering the inclusion of a P3.00 daily wage increase in the computation of the final award.

RULING

The Supreme Court ruled that the RTC has no jurisdiction over the subject matter. The action filed by the Company, although labeled as an action for annulment of judgment, is in substance a challenge to a final labor arbiter’s decision. Jurisdiction over such execution and enforcement of labor decisions is vested by law exclusively in the Labor Arbiters and the NLRC. The Court emphasized that the RTC cannot interfere through injunctive relief, as this would undermine the finality of labor decisions and the statutory framework designed for their speedy implementation. The Company’s proper remedy was to seek relief within the labor tribunal system, not through an ordinary civil action.
Regarding the NLRC’s order to include a P3.00 daily increase, the Court found no grave abuse of discretion. The increase stemmed from statutory Wage Orders (Nos. 5 and 6). The records showed the Company’s exemptions from these orders had expired by the time of the NLRC’s 1987 resolution. Therefore, the NLRC correctly directed the integration of these mandatory wage adjustments into the computation of the final monetary award due to the workers, ensuring full compliance with the law.
The petitions were consolidated and disposed of accordingly. In G.R. No. 75851 , the Court granted the Union’s petition, ordering the dismissal of the RTC case for lack of jurisdiction. In G.R. No. 79417, the Company’s petition was dismissed for lack of merit. The NLRC was directed to proceed with the computation and execution of the final award, including applicable statutory wage increases.