Facts:

The case involves Bionic Heavy Equipments, Inc. and Mr. Spencer Forkner as petitioners against the National Labor Relations Commission (NLRC) and NAFLU/Amie Tomentos, et al. as respondents. The dispute originated from a decision rendered by Labor Arbiter Jose G. Gutierrez on December 1, 1989, in favor of the complainants, which included the National Federation of Labor Unions. The decision ordered Bionic Heavy Equipments, Inc. to pay various monetary awards to the complainants, including separation pay, ECOLA, service incentive leave, 13th month pay, overtime pay, and back wages totaling P21,415,486.00. The decision was received by the private respondent on January 23, 1990, and an appeal was filed on February 2, 1990, without the necessary cash or surety bond, which led to a series of motions and hearings regarding the execution of the decision. The labor arbiter granted a writ of execution on July 5, 1990, citing that the appeal was not perfected due to the absence of a bon...

Facts:

Background of the Case: The case originated from a labor dispute involving Bionic Heavy Equipment, Inc. and its employees, represented by the National Federation of Labor Unions (NAFLU). On December 1, 1989, Labor Arbiter Jose G. Gutierrez ruled in favor of the employees, ordering Bionic to pay various monetary awards, including separation pay, ECOLA, service incentive leave, 13th-month pay, overtime pay, night shift differentials, premium pay on holidays and rest days, and three years of backwages.

Appeal and Execution: Bionic received the decision on January 23, 1990, and filed an appeal memorandum on February 2, 1990, within the reglementary period. However, Bionic failed to post a cash or surety bond, which is required to perfect an appeal. The labor arbiter granted a motion for immediate issuance of a writ of execution on June 27, 1990, based on the computation of the monetary award, which amounted to P21,415,486.00.

Auction Sale and NLRC Intervention: On July 19, 1990, a public auction sale of Bionic's properties was conducted, despite a restraining order issued by the National Labor Relations Commission (NLRC) on the same day. The NLRC later quashed the writ of execution and ordered the return of the properties sold, which were to remain in custodia legis until the amount of the bond to be posted by Bionic could be determined.

Supreme Court Decision: The Supreme Court, in a related case (G.R. No. 94540-41), dismissed NAFLU's petition and ordered the NLRC to resolve Bionic's appeal. The NLRC, in its August 14, 1991 decision, vacated the labor arbiter's decision and remanded the case for further proceedings to determine the appropriate monetary awards.

Subsequent Proceedings: Bionic filed a motion to release the proceeds of the auction sale, which was granted by Labor Arbiter Villahermosa on May 18, 1993. NAFLU appealed this order, and the NLRC, in its September 26, 1994 resolution, set aside the order, directing the labor arbiter to terminate the hearing and fix the amount of the bond based on the monetary awards to be rendered.

Issue:

1. Whether the proceeds of the auction sale should remain in custodia legis in accordance with the NLRC's August 10, 1990 Order.
2. Whether the NLRC committed grave abuse of discretion in directing the labor arbiter to immediately terminate the hearing to fix the amount of the bond.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court granted Bionic's petition, reinstating the May 18, 1993 Order of Labor Arbiter Villahermosa and directing the labor arbiter to proceed with the resolution of the case. The Court emphasized the importance of due process and the need for substantial evidence in labor cases.