Case Digest (G.R. No. 117232)
Facts:
Co Tuan, Samuel Ang, Jorge Lim, and Edwin Gotamco v. National Labor Relations Commission and Confederation of Labor Unions of the Philippines, G.R. No. 117232, April 22, 1998, the Supreme Court Third Division, Purisima, J., writing for the Court.Petitioners (private purchasers) owned five parcels of land that were levied upon to satisfy a final and executory NLRC judgment in favor of the private respondent Confederation of Labor Unions of the Philippines (CLUP) against Buda Enterprises. On August 31, 1987 a Labor Arbiter rendered judgment for CLUP against Buda Enterprises for unfair labor practice, illegal dismissal and monetary claims; the decision became final and a writ of execution issued leading to the levy on the parcels.
Upon learning of the levy, petitioners filed on January 21, 1988 an Urgent Motion to Quash the Writ of Execution, asserting valid title by virtue of an Extra-Judicial Settlement and Sale executed on August 25, 1987 by heirs of the deceased Edilberto Soriano (one heir being Lourdes Soriano, Buda’s proprietress). The Labor Arbiter granted the motion, and CLUP appealed to the National Labor Relations Commission (NLRC), asking that the Arbiter be ordered to implead the movants and to inquire whether the sale was fraudulently made to evade payment of labor claims.
On May 31, 1991 the NLRC directed the Labor Arbiter to implead the movants and conduct a hearing to determine if the sale was made to evade payment and to resolve related incidents. Labor Arbiter Numeriano Villena, however, on June 25, 1992, held his office incompetent to determine whether fraud tainted the sale. CLUP appealed that ruling; the NLRC reversed the Arbiter, finding that the Arbiter erred in not impleading the movants and reiterating its order to conduct a hearing.
Petitioners brought a special civil action for certiorari and prohibition with preliminary injunction to the Supreme Court, assailing the NLRC’s authority to adjudicate the validity of the sale (claiming such determination is judicial and beyond the NLRC’s competence) and invoking this Court’s decision in Asian Footwear v. Soriano. CLUP relied on Section 2, Rule VI of the NLRC Manual of Instructions for Sheriffs as authorizing the NLRC/Arbiter to hear third-party claims; the NLRC argued the petition was premature for failure to move for reconsideration. The Solicitor General filed a manifestation noting the NLRC erred to the extent it proposed to determine the effect of a commitment al...(Subscriber-Only)
Issues:
- Did the NLRC have jurisdiction/competence to determine the validity of the sale and whether the sale was made in fraud of creditors (i.e., to decide title and fraud affecting property levied under execution)?
- Was the petition premature for failure to file a motion for reconsideration with the NLRC?
- Were petitioners estopped from contesting the NLRC’s authority after filing a Mo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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