A.M. No. 24-02-09-SC - Re: Draft Department of Justice-National Prosecution Service's Rules on Preliminary Investigations and Inquest Proceedings

Petitioner DMCI Project Developers, Inc. (DMCI) claims ownership over a parcel of land (subject lot) of 16,461 square meters in Taguig City, covered by Transfer Certificate of Title (TCT) No. 25491 originally issued to Honorato Lacsina and others.
Respondents Nelia Bernadas, Noel Batanes, Eduardo Nonsol, Jose Balde, Elmor Mabatan, and Lilio Rebueno (Bernadas et al.) were labor claimants who filed a labor case with the National Labor Relations Commission (NLRC) against the original owners and Liberty Transport Corp.

The NLRC ruled in favor of Bernadas et al., resulting in a Notice of Levy annotated on the TCT No. 25491 on March 15, 2006, affecting the registered owners’ interest in the property.
An auction sale of the property was conducted on April 3, 2009, where Bernadas et al. emerged as winning bidders.
The Register of Deeds annotated the Certificate of Sale on June 3, 2009 on TCT No. 25491 in favor of Bernadas et al., indicating the sale for P1,915,800.

On June 29, 2009, Bernadas et al. executed a Deed of Sale/Certificate of Redemption of Real Property and a Release and Quitclaim in favor of DMCI after receiving payment equivalent to their monetary award from DMCI.
Both DMCI and Bernadas et al. filed a petition before the Register of Deeds to cancel the Notice of Levy and the Certificate of Sale annotations.

Taguig Land Development Corporation (Taguig Land) acquired the subject lot and secured TCT No. 12619, which was later merged into DMCI’s ownership.
Bernadas et al. subsequently filed a motion before the NLRC to nullify the Deed of Sale and Release, alleging the documents were spurious and had been falsified and that they were prejudiced by receiving only P100,000 instead of the full claim amount.
DMCI opposed the motion, claiming Evelyn Insilay-Rebueno (Evelyn), representing Bernadas et al. as attorney-in-fact, lacked authority since Bernadas et al. had already been fully paid, thereby extinguishing her agency. Further, DMCI argued Bernadas et al. already received full payment, and the case should be dismissed.

On January 4, 2011, Labor Arbiter Antonio R. Macam granted Bernadas et al.'s motion, nullifying the Deed of Sale/Certificate of Redemption and the Release and Quitclaim, ordering cancellation of TCT No. 12619 and reissuance of a new TCT in favor of Bernadas et al.
The LA held DMCI had no personality to redeem since it was not a redemptioner under NLRC Manual and could not be considered a successor-in-interest.
The NLRC affirmed the LA's order on May 27, 2011, and Declared the Decision final and executory on July 19, 2011 through an Entry of Judgment.
DMCI filed a Manifestation and Motion to Recall Entry of Judgment on August 25, 2011, alleging prematurity since the NLRC had yet to rule on their motion for reconsideration.

DMCI filed a Complaint for Quieting of Title before RTC Branch 266 of Pasig City and secured a Temporary Restraining Order (TRO) dated April 19, 2012, enjoining Bernadas et al. from enforcing the levy on TCT No. 25491 followed by a Preliminary Injunction issued on October 22, 2012.
On May 16, 2012, the NLRC issued a subsequent Entry of Judgment confirming that the prior Resolution denying their motion for reconsideration had become final and executory.

The Register of Deeds elevated the matter to the Land Registration Authority via consulta on two issues:

Whether the NLRC has the power to order cancellation of a title already issued in favor of Taguig Land Development Corporation, and
Whether the order covers the entire property, including shares of non-parties to the labor case.

On April 3, 2013, the LRA ruled that the January 4, 2011 LA Order and the July 19, 2011 Entry of Judgment are registrable, relying on this Court’s ruling in Tanongon v. Samson recognizing the authority of NLRC to execute final judgments involving levied properties.
DMCI's Motion for Reconsideration before the LRA was denied on September 26, 2013.
DMCI filed a Petition for Review with the Court of Appeals (CA), which denied their petition in a Decision dated June 5, 2015 and a Resolution dated December 15, 2015, affirming the LRA rulings.

DMCI filed the present Petition for Review on Certiorari, assailing the CA rulings and the LRA decisions, arguing among others:

The NLRC Order should not be implemented or registered without a writ of execution.
The CA disregarded the recent motion denying issuance of writ of execution by the LA dated June 19, 2015.
The CA overlooked DMCI’s pending quieting of title case and the existing injunction, affecting ownership issues.

Respondents maintain that the LRA and CA decisions are consistent with law and jurisprudence, emphasizing Bernadas et al.’s ownership rights upheld in previous rulings.

Whether the Court of Appeals gravely erred in sustaining the LRA Resolution and Order declaring the NLRC's January 4, 2011 Order and related Entry of Judgment registrable despite the absence of a writ of execution.
Whether the NLRC has the power to order the cancellation of a title already issued in the name of Taguig Land Development Corporation, including non-parties’ shares.
Whether the absence or denial of a writ of execution affects the registrability and implementation of the NLRC’s orders regarding the subject lot.
Whether the existence of DMCI’s quieting of title case and the RTC’s injunction affects the effectivity of the NLRC’s orders and the subsequent registration actions.