Facts:

This case involves Ma. Fe Bacos (Petitioner) and Domingo Arcega (Respondent). The events began on February 11, 1998, when Arcega filed a complaint for illegal dismissal and other monetary claims against Viabel International Garments, Inc. and/or Marlon Viado, with the Labor Arbiter in Banawe, Quezon City, under NLRC-NCR Case No. 00-02-01455-98. On February 25, 1999, Labor Arbiter Daisy G. Cauton-Barcelona issued a decision favoring Arcega, declaring the dismissal illegal and ordering Viabel and Viado to pay Arcega various monetary claims totaling P90,000.00 in back wages, P45,000.00 in separation pay, P5,192.40 in service incentive leave pay, P27,000.48 in 13th-month pay, and P16,719.28 in attorney's fees, while dismissing claims for moral and exemplary damages for lack of merit. After Viabel and Viado failed to appeal, the decision became final and executory on May 21, 1999, and a writ of execution was issued. On June 8, 1999, twenty-eight sewing machines were levied by the

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Facts:

Background on the Original Case

• On February 11, 1998, respondent Domingo Arcega filed a complaint for illegal dismissal and other monetary claims against Viabel International Garments, Inc. and/or Marlon Viado before the Labor Arbiter in Banawe, Quezon City.
• The case, docketed as NLRC-NCR Case No. 00-02-01455-98, eventually resulted in a decision ruling that the dismissal was illegal, with corresponding orders for payment of backwages, separation pay, service incentive leave pay, 13th month pay, and attorney’s fees.
• On May 21, 1999, the decision became final and executory due to the failure of Viabel and/or Marlon Viado to appeal.

Execution Proceedings and Third-Party Claim

• On June 8, 1999, in the course of executing the decision, the NLRC sheriff levied twenty-eight sewing machines belonging to Viabel and/or Marlon Viado with a public auction set on June 17, 1999.
• On the same day of the levy, petitioner Ma. Fe Bacos filed a notice of third-party claim with the NLRC, asserting that the machines had been previously sold to her by Marlon Viado for P150,000.00, as evidenced by a Deed of Absolute Sale notarized on January 26, 1998 by Notary Public Mario Ramos.

Proceedings on the Third-Party Claim

• Labor Arbiter Daisy G. Cauton-Barcelona, on January 10, 2000, dismissed the third-party claim on the ground that the Deed of Absolute Sale appeared spurious.
• On appeal, both the NLRC (Resolution dated August 31, 2000) and its motion for reconsideration (Resolution dated February 1, 2001) maintained the dismissal of the claim.
• Subsequently, petitioner filed a petition for certiorari before the Court of Appeals (CA-G.R. SP No. 64177), challenging the dismissal of her third-party claim.

Court of Appeals Decision and Subsequent Proceedings

• On November 9, 2001, the Court of Appeals (Tenth Division) dismissed petitioner’s petition, holding that she failed to substantiate her claim of ownership of the levied sewing machines.
• The appellate court noted the absence of convincing evidence to support the authenticity of the Deed of Absolute Sale, including the lack of notarized reports or copies on file with the Clerk of Court, and the failure of the petition to specify details regarding the acquisition of the machines.
• Petitioner’s subsequent motion for reconsideration was denied on February 19, 2002, prompting her to file the present petition for review on certiorari.

Issue:

Sufficiency of Evidence to Establish Ownership

• Whether petitioner Ma. Fe Bacos met the evidentiary requirement to establish her title or right to possession of the levied sewing machines under the third-party claim by merely submitting an affidavit in accordance with Section 16, Rule 39 of the 1997 Rules of Civil Procedure.
• Whether the submission of a purported Deed of Absolute Sale, which the Labor Arbiter and the NLRC regarded as spurious, could be deemed sufficient to prove her ownership of the property.

Interpretation of Procedural Requirements

• Whether Section 16, Rule 39 of the 1997 Rules of Civil Procedure—and the corresponding provisions of Sections 2 and 3 of the NLRC Manual of Instructions for Sheriffs—only require an affidavit of title or if they demand more specific evidence, including the circumstances that validate the claim to ownership.
• Whether the petitioner’s failure to specify the date and the source of acquisition, as well as to attach an authenticated copy of the deed, constitutes a fatal flaw in her third-party claim.

Implications of Documentary Deficiencies

• Whether the absence of the notarized copy of the Deed of Absolute Sale from the Clerk of Court’s records itself is a strong indicator of fraud and simulation, thereby undermining the validity of petitioner’s claim.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)