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PAQUITO V. ANDO v. ANDRESITO Y. CAMPO

FACTS:

Petitioner Paquito V. Ando was the president of Premier Allied and Contracting Services, Inc. (PACSI), an independent labor contractor. Respondents were hired by PACSI as pilers or haulers. In June 1998, respondents were dismissed by PACSI and they filed a case for illegal dismissal and money claims with the National Labor Relations Commission (NLRC). The Labor Arbiter ruled in favor of respondents, ordering PACSI and petitioner to pay a total of P422,702.28. Petitioner and PACSI appealed but their appeal was dismissed. NLRC issued a Notice of Sale on Execution of Personal Property to answer for the monetary award. Petitioner filed an action for prohibition and damages before the Regional Trial Court (RTC), claiming that the property subject to execution belonged to him and his wife, not the corporation. RTC denied petitioner's prayer for a temporary restraining order (TRO) and ruled that his remedy was to file a third-party claim with the NLRC Sheriff. Petitioner filed a petition for certiorari with the Court of Appeals (CA) which affirmed the RTC's lack of jurisdiction but nullified other pronouncements in the same Order. Petitioner sought nullification of the CA decision, arguing that he was never sued in his personal capacity and that he can choose between filing a third-party claim or a separate action.

ISSUES:

  1. Whether the RTC has jurisdiction to restrain the implementation of the writ of execution issued by the Labor Arbiter.

  2. Whether the petitioner can choose between filing a third-party claim with the sheriff of the NLRC or filing a separate action.

RULING:

  1. The regular courts do not have jurisdiction to hear and decide questions arising from and incidental to the enforcement of decisions, orders, or awards rendered in labor cases by appropriate officers and tribunals of the Department of Labor and Employment. The NLRC Manual on the Execution of Judgment governs any question on the execution of a judgment of that body. Therefore, the RTC did not err in upholding its lack of jurisdiction to restrain the implementation of the writ of execution issued by the Labor Arbiter.

  2. The petitioner can choose between filing a third-party claim with the sheriff of the NLRC or filing a separate action. Section 16, Rule 39 of the Rules of Court on third-party claims applies by analogy or in a suppletory character to labor cases. Thus, the petitioner has the option to file a third-party claim or a separate action to question the manner of execution of the judgment.

PRINCIPLES:

  • Regular courts have no jurisdiction to hear and decide questions arising from and incidental to the enforcement of decisions, orders, or awards rendered in labor cases by appropriate officers and tribunals of the Department of Labor and Employment.

  • The NLRC Manual on the Execution of Judgment governs any question on the execution of a judgment in labor cases.

  • Section 16, Rule 39 of the Rules of Court on third-party claims applies by analogy or in a suppletory character to labor cases.