Case Digest (G.R. No. 94348)
Facts:
- Tadeo M. Cangco is the petitioner; the respondents are the Court of Appeals and Polymer Consult, Inc.
- The case originated on June 29, 1987, when Labor Arbiter Edgardo Magno issued a writ of execution against Polymer Consult, Inc. in a labor dispute involving Manuel Duenas.
- On August 18, 1987, NLRC Deputy Sheriff Paz Mercado levied a parcel of land in Taytay, Rizal, registered under Polymer's name.
- Polymer retained possession of the property but filed an omnibus motion to quash the writ of execution on October 23, 1987, citing errors in the monetary award computation.
- Cangco purchased the parcel of land at an auction on October 26, 1987, and received a certificate of sale after full payment.
- The Labor Arbiter reduced the monetary award on November 9, 1987, but did not quash the writ of execution.
- Polymer appealed the decision, and during the appeal, the one-year redemption period expired, leading to a final bill of sale in favor of Cangco on May 25, 1989.
- Cangco obtained a transfer certificate of title on June 30, 1989, and filed Land Registration Case No. 740-A on November 21, 1989, seeking a writ of possession.
- The Regional Trial Court issued the writ ex parte, and the property was delivered to Cangco on March 1, 1990.
- Polymer filed a petition for certiorari with the Court of Appeals, claiming the trial court exceeded its jurisdiction.
- On June 13, 1990, the Court of Appeals granted Polymer's petition, leading Cangco to file a Petition for Review with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the Court of Appeals' decision that the Regional Trial Court lacked jurisdiction to issue a writ of possession in this case.
- The Court upheld the annulment of the proceedings in Land Re...(Unlock)
Ratio:
- The Supreme Court's ruling was based on the Labor Code, particularly Article 217, which grants exclusive jurisdiction to Labor Arbiters and the NLRC over money claims from labor disputes.
- The enforcement of decisions in labor cases is under the jurisdiction of labor officials, not regular courts.
- Article 224(a) allows Labor Arbiters to issue writs of execution for enforcing final awards, while Article 254 prohibits regular courts from intervening in labor disputes.
- Cangco's applicati...continue reading
Case Digest (G.R. No. 94348)
Facts:
The case involves Tadeo M. Cangco as the petitioner and the Court of Appeals and Polymer Consult, Inc. as the respondents. The events leading to this case began on June 29, 1987, when Labor Arbiter Edgardo Magno issued a writ of execution to enforce a final decision against Polymer Consult, Inc. in NLRC-NCR Case No. 1-079-83, which was a labor dispute involving Manuel Duenas. On August 18, 1987, NLRC Deputy Sheriff Paz Mercado levied a parcel of land in Taytay, Rizal, registered under Polymer's name. Although Polymer was allowed to retain possession of the property, on October 23, 1987, it filed an omnibus motion to quash the writ of execution, claiming an error in the monetary award computation due to Duenas.
On October 26, 1987, Cangco, as the highest bidder, purchased the parcel of land during an auction conducted by Sheriff Mercado, who issued a certificate of sale upon Cangco's full payment. On November 9, 1987, the Labor Arbiter issued an order that reduced the monetary award but did not quash the writ of execution. Polymer appealed this decision to the NLRC, contesting the refusal to quash the writ. During the appeal, the one-year redemption period for the property expired, leading to the issuance of a final bill of sale in favor of Cangco on May 25, 1989. Cangco then executed an affidavit of consolidation and obtained a transfer certificate of title on June 30, 1989.
On November 21, 1989, Cangco filed Land Registration Case No. 740-A with the Regional Trial Court of Antipolo, seeking a writ of possession. The court issued the writ ex parte, and the property was delivered to Cangco on March 1, 1990. Polymer, upon learning of this, filed a...