Title
Batong Buhay Gold Mines, Inc. vs. Dela Serna
Case
G.R. No. 86963
Decision Date
Aug 6, 1999
Employees sued BBGMI for unpaid wages; Regional Director ordered payment. Auction sales void due to mortgaged properties; jurisdiction upheld under Labor Code.

Case Digest (G.R. No. 86963)

Facts:

Batong Buhay Gold Mines, Inc. v. Hon. Dionisio Dela Serna, G.R. No. 86963, August 06, 1999, Supreme Court Third Division, Purisima, J., writing for the Court. Petitioner Batong Buhay Gold Mines, Inc. (BBGMI) sought certiorari under Rule 65 to annul three administrative orders issued by respondent Undersecretary Dionisio Dela Serna of the Department of Labor and Employment (DOLE) dated September 16, 1988, December 14, 1988 and February 13, 1989. The employee-complainants (including Elsie Rosalinda Ty, Antonio Mendelebar, Ma. Concepcion Q. Reyes and others) had filed a labor standards complaint on February 5, 1987 for unpaid wages, ECOLA/wage differentials, 13th month pay, leave benefits and related claims. The Regional Director, through Labor Standards and Welfare Officers (LSWOs), recommended payment of P4,818,746.40; on July 31, 1987 the Regional Director issued an order directing BBGMI to pay that amount.

After the Regional Director ordered payment, the complainants moved for issuance of a writ of execution. The Regional Director required BBGMI to post a cash or surety bond; when BBGMI failed to do so, a writ of execution dated September 14, 1987 was issued and Special Sheriff John Ramos executed seizures and conducted public auctions of BBGMI's personal properties on several dates in September and October 1987. BBGMI later posted a supersedeas bond, prompting the Regional Office to restrain enforcement by order dated January 26, 1988. BBGMI appealed the July 31, 1987 Regional Director order to Undersecretary Dela Serna.

In his September 16, 1988 order the Undersecretary affirmed the Regional Director’s jurisdiction and declared all auction sales conducted by the special sheriff null and void. Motions for reconsideration followed; on December 14, 1988 the Undersecretary modified his prior order to exclude from annulment certain properties sold on October 29, 1987 that intervenors MFT Corporation and Salter Holdings Pty. Ltd. claimed as purchasers for value. BBGMI challenged the three orders as tainted with grave abuse of discretion amounting to lack or excess of jurisdiction and filed the present petition for certiorari.

Below the Court scrutinized two primary questions: (1) whether the Regional Director had jurisdiction to decide the labor standards case; and (2) whethe...(Subscriber-Only)

Issues:

  • Did the Regional Director have jurisdiction to hear and decide the labor standards complaint of BBGMI’s employees?
  • Were the execution auctions conducted by Special Sheriff John Ramos valid and did intervenors acquire good title from...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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