G.R. No. 101723 - Industrial Management International Development Corp. vs. National Labor Relations Commission

In September 1984, Enrique Sulit, Socorro Mahinay, Esmeraldo Pegarido, Tita Bacusmo, Gino Niere, Virginia Bacus, Roberto Nemenzo, Dario Go and Roberto Alegarbes (private respondents) filed a complaint for separation pay and unpaid wages with the Department of Labor and Employment, Regional Arbitration Branch No. VII in Cebu City, naming as respondents Filipinas Carbon and Mining Corporation, Gerardo Sicat, Antonio Gonzales, Chiu Chin Gin, Lo Kuan Chin, and Industrial Management International Development Corp. (INIMACO).
On March 10, 1987, Labor Arbiter Tumamak rendered a Decision ordering the six corporate and individual respondents to pay a total of ₱138,588.31 to four complainants, to be deposited with the Commission within ten days. No appeal was taken, and the Decision became final and executory.

June 16, 1987 – Writ of Execution issued; returned unsatisfied.
August 26, 1987 – Alias Writ of Execution issued, commanding levy against movable or immovable properties of “Antonio Gonzales/INIMACO and/or Filipinas Carbon and Mining Corp. and Gerardo Sicat,” thereby implying solidary liability.
September 3, 1987 – INIMACO filed a Motion to Quash the Alias Writ and Set Aside the Decision, contending that the writ altered the dispositive portion by converting joint liability into solidary; denied by the Arbiter on September 14, 1987.
October 2, 1987 – INIMACO appealed to the NLRC; on August 31, 1988, the NLRC dismissed the appeal, ruled that respondents were liable “jointly and severally,” waived procedural irregularities, and upheld the writ.
July 31, 1989 – INIMACO moved to compel the sheriff to accept its pro rata payment of ₱23,198.05 as full satisfaction of its share; denied by the Arbiter on August 15, 1989; appeal to NLRC likewise dismissed in its September 4, 1991 Resolution.
November 1991 – INIMACO filed the present petition for certiorari before the Supreme Court, alleging grave abuse of discretion by the NLRC in affirming the solidary liability.

Whether the liability of INIMACO (and co-respondents) under the final and executory March 10, 1987 Decision is solidary or merely joint.