G.R. No. 153882 - Lingkod Manggagawa sa Rubberworld vs. Rubberworld

Petitioner: Lingkod Manggagawa sa Rubberworld, Adidas-Anglo, a legitimate labor union representing employees of Rubberworld Philippines, Inc. (a domestic corporation manufacturing footwear, bags, and garments).
Respondents: Rubberworld (Phils.) Inc. and Antonio Yang, with Laya Mananghaya Salgado & Co., CPAas acting in its capacity as liquidator of the corporation.

On August 26, 1994, Rubberworld filed a Notice of Temporary Partial Shutdown with the Department of Labor and Employment (DOLE) due to severe financial crisis, effective September 26, 1994. A copy of the notice was served on the recognized union, Bisig Pagkakaisa-NAFLU.
On September 1, 1994, Bisig Pagkakaisa-NAFLU staged a strike by setting up a picket line and welding the corporation’s gate, leading to an early closure of the company’s premises before the intended shutdown date.

On September 9, 1994, Lingkod Manggagawa sa Rubberworld, represented by its President Sonia Esperanza, filed a complaint against Rubberworld and its Vice Chairperson Antonio Yang.
The complaint, docketed as NLRC-NCR-Case No. 00-09-06637, alleged unfair labor practice (ULP), illegal shutdown, and non-payment of salaries and separation pay, also claiming that the strike was company-instigated or supported.

On November 22, 1994, while the Labor Arbiter’s complaint was pending, Rubberworld filed a Petition for Declaration of a State of Suspension of Payments with the SEC.
The SEC granted the petition on December 28, 1994, and issued a suspension order that automatically stayed all actions for claims against Rubberworld pending before any judicial or quasi-judicial body.
Despite this order and Rubberworld’s Motion to Suspend Proceedings submitted on January 10, 1995, Labor Arbiter Ernesto Dinopol proceeded with the ULP case.

Denying Rubberworld’s motion to suspend proceedings.
Declaring Rubberworld to have committed an unfair labor practice.
Declaring the temporary shutdown officially ended as of March 26, 1995.
Ordering Rubberworld to reinstate union members (opting for reinstatement within one month) or pay backwages and separation pay plus a 10% attorney’s fee.

The decision also directed the computation of awards by an NLRC Research and Information Unit officer, subsequently resulting in a computed total award of approximately ₱27.5 million.

On September 21, 1995, Rubberworld went on appeal to the NLRC, posting a temporary appeal bond of ₱500,000.
On January 22, 1996, the First Division of the NLRC required Rubberworld to post an upgraded appeal bond equivalent to the computed award (₱27,506,255.70) and warned that failure to do so would result in dismissal for non-perfection of appeal.
Rubberworld’s motion for reconsideration regarding the bond issue was denied by the NLRC in its Resolution dated March 29, 1996, leading eventually to the dismissal of its appeal on June 28, 1996.
On April 22, 1998, the SEC declared Rubberworld dissolved and lifted the suspension order, appointing Laya Mananghaya Salgado & Co., CPAas as liquidator.

Faced with a writ of execution issued on August 18, 1995 in favor of the union and further adverse rulings, Rubberworld filed a Petition for Certiorari challenging the jurisdiction and the requirement to post an upgraded appeal bond.
A supplemental petition challenged the NLRC’s dismissal order, alleging that the labor tribunal acted without or in excess of jurisdiction by proceeding notwithstanding the SEC suspension order.
On February 8, 1999, Rubberworld sought to amend its petition arguing that the Labor Arbiter should have suspended proceedings under the SEC order. The Court referred the amended petition to the CA (docketed as CA-G.R. SP No. 53356).
Eventually, on January 18, 2002, the Court of Appeals (CA) granted Rubberworld’s petition, annulling the Labor Arbiter’s decision and nullifying subsequent NLRC orders (including the writ of execution) on the ground that the proceedings occurred in violation of the SEC suspension order.

Whether the CA committed grave abuse of discretion amounting to lack of jurisdiction or an excess thereof by giving due course to Rubberworld’s petition—which sought to annul the Labor Arbiter’s decision and subsequent NLRC orders—even though those decisions were argued to have become final and executory.

Whether the CA erred in applying Section 5(d) and Section 6(c) of PD No. 902-A (as amended) to the labor dispute, particularly in light of the SEC’s suspension order mandating the suspension of all claims against corporations under management or receivership.

Whether the CA committed reversible error when adopting and applying the rulings in the cases of Rubberworld (Phils.), Inc. (or Julie Yap Ong v. NLRC, Marilyn F. Arellano, et al.) and Rubberworld (Phils.), Inc. and Julie Y. Ong v. NLRC, Aquino Magsalin, et al., and if such precedents should bind the instant case.