Facts:

This case involves a Petition for Indirect Contempt filed by the petitioner, Bank of the Philippine Islands (BPI), against several respondents including Labor Arbiter Roderick Joseph Calanza, Sheriff Enrico Y. Paredes, and former employees Amelia Enriquez and Remo L. Sia. The case originated from the termination of Enriquez and Sia, who held the positions of branch manager and assistant branch manager at BPI's Bacolod-Singcang Branch, respectively. On September 3, 2003, they were dismissed for alleged breach of trust and dishonesty. The next day, Enriquez and Sia filed separate complaints for illegal dismissal with the National Labor Relations Commission (NLRC) in Bacolod City. After evaluating the evidence, Executive Labor Arbiter Danilo C. Acosta ruled on March 29, 2004, that their dismissals were illegal and ordered their reinstatement with full back wages amounting to ₱1,173,434.50.

BPI appealed this decision to the NLRC, which ultimately reversed Arbiter Acosta’s rulin

...

Facts:

Background of the Employment Dispute

• Bank of the Philippine Islands (BPI) dismissed Enriquez (branch manager) and Sia (assistant branch manager) on September 3, 2003 for alleged breach of trust, confidence, and dishonesty.
• Following their dismissal, both Enriquez and Sia filed separate complaints for illegal dismissal before the National Labor Relations Commission (NLRC), Regional Arbitration Branch No. VI in Bacolod City.

Development of Decisions and Reinstatement

• After submission of their respective position papers, Labor Arbiter Danilo C. Acosta rendered a decision on March 29, 2004 declaring the employees were illegally dismissed, ordering their reinstatement and payment of full back wages amounting to P1,173,434.50.
• In implementation of the decision, Enriquez and Sia were reinstated into BPI’s payroll.

Reversal of the Reinstatement Order

• Petitioner BPI appealed the reinstatement decision before the NLRC, which ruled that BPI had just cause in dismissing the employees.
• The NLRC reversed and set aside the Labor Arbiter’s decision and, although dismissing the complaint, ordered BPI to provide financial assistance equivalent to one‑half month’s pay for each year of service.
• The Court of Appeals (CA) later affirmed the NLRC’s decision in its entirety on November 30, 2005, and the matter eventually ascended to the Supreme Court (docketed as G.R. No. 172812).

Motion for Partial Execution and Issuance of the Writ

• While the petition was pending before the Supreme Court, Enriquez and Sia filed a motion for partial execution of the Labor Arbiter’s decision, asserting that the reinstatement order was immediately executory pending appeal.
• On October 13, 2007, Labor Arbiter Roderick Joseph Calanza granted the motion based on jurisprudence (citing Roquero and Air Philippines Corporation v. Zamora), thereby authorizing the issuance of a corresponding writ of execution.
• Following the issuance, Sheriff Enrico Y. Paredes served BPI a notice of sale for a parcel of its land to satisfy the alleged monetary obligation.

Intervention by Petitioner and Subsequent Court Orders

• In response to the notice of sale and the conduct of the Labor Arbiter, BPI immediately filed an Urgent Petition for Injunction with the NLRC, Fourth Division in Cebu City, which resulted in the issuance of a Temporary Restraining Order on November 26, 2007.
• Dissatisfied with the actions of Labor Arbiter Calanza, Sheriff Paredes, Enriquez, and Sia, and in view of the pending Supreme Court appeal (G.R. No. 172812), BPI subsequently filed the present petition for indirect contempt.
• The controversy centered on the alleged premature and unlawful execution of the writ and the reliance on jurisprudence which BPI contended was inapplicable given the finality of the NLRC decision.

Final Developments Relevant to the Contempt Allegation

• On February 12, 2008, the Supreme Court denied the petition filed by Enriquez and Sia, sustaining the NLRC and CA decisions that validated their dismissal.
• On June 30, 2008, the NLRC granted BPI’s petition for injunction, nullifying the Labor Arbiter’s order and the writ of execution.
• Labor Arbiter Calanza, on October 27, 2008, issued an order closing the case based on Enriquez and Sia’s motion to dismiss once their claims were satisfied and fully paid.
• The core factual issue remaining was whether the acts by the respondents amounted to indirect contempt of court.

Issue:

Whether the following acts qualify as indirect contempt under Section 3, Rule 71 of the Rules of Court:

• The filing by Enriquez and Sia of the motion for partial execution of the reinstatement order.
• Labor Arbiter Calanza’s issuance of a writ of execution on the basis that the reinstatement order should be enforced pending finality of appellate review.
• Sheriff Paredes’ subsequent service of the notice of sale against BPI’s property pursuant to the writ of execution.

• Whether these acts demonstrated a willful disobedience or defiance of the court’s authority and thereby compromised the integrity and administration of justice as required under the definition of indirect contempt.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)