Case Digest (G.R. No. 132453)
Facts:
National Electrification Administration (NEA) v. Hon. Feliciano V. Buenaventura, G.R. No. 132453, February 14, 2008, the Supreme Court Second Division, Carpio Morales, J., writing for the Court.Petitioner NEA, represented by its Administrator Teodorico Sanchez and the NEA Management Team (represented by Project Manager Danilo Cruz), sought review of the Regional Trial Court (RTC), Branch 30, Cabanatuan City decision dismissing NEA’s complaint for injunction and declaration of nullity of executions; respondents were Hon. Feliciano V. Buenaventura as RTC judge, Labor Arbiter Dominador B. Saludares, and NLRC deputy sheriff Antonio T. Datu. The dispute traces to rehabilitation loans and mortgage/security arrangements between NEA and Nueva Ecija III Electric Cooperative, Inc. (NEECO III).
From 1986–1988 NEA extended loans to NEECO III and took a mortgage over the cooperative’s assets; pursuant to a re-lending agreement and Presidential Decree No. 1645 NEA designated a project supervisor/acting general manager and advanced funds to settle NEECO III’s obligations to NPC. NEECO III defaulted on amortizations; NEA approved foreclosure by Board Resolution No. 42 (June 25, 1992) and undertook acts attendant to NEECO III’s dissolution. Former employees of NEECO III (led by Josephine Manuel et al.) filed labor complaints for illegal dismissal and backwages. By Decision of December 29, 1992, Labor Arbiter Ariel C. Santos ordered reinstatement and backwages in favor of Manuel et al.; that decision survived NLRC proceedings and a petition to this Court docketed as G.R. No. 110509 which this Court dismissed on July 25, 1994 (motion for reconsideration likewise denied).
An NLRC Partial Writ of Execution issued November 21, 1994; NEA filed an affidavit of third-party claim which the Labor Arbiter denied for failure adequately to prove NEA’s legal ownership. Subsequent administrative and NLRC proceedings culminated in the NLRC entering judgment (September 30, 1996) and denying NEA’s urgent motion to vacate (October 7, 1996). NEA then filed a certiorari petition with application for TRO and injunction (G.R. No. 126571) on October 18, 1996, which this Court dismissed by Resolution of November 18, 1996 for failure to submit proof of service.
While NEA’s Board adopted Resolution No. 63 (November 20, 1996) authorizing disposition of NEECO III assets by dacion en pago and public bidding, Manuel et al. secured an Alias Partial Writ of Execution (issued by Labor Arbiter Saludares on November 7, 1997) to collect the award or levy NEECO III properties and effect reinstatement. On November 26, 1997 the NEA Management Team filed before the RTC (Civil Case No. 2934-AF) a complaint for injunction, declaration of nullity of executions/garnishments, and related reliefs against Saludares and Datu, alleging forcible entry and seizure of NEA premises and property; the same day NEA filed a Motion to Quash the Alias Partial Writ with the NLRC. Branch 30 initially granted a temporary restraining order.
In their pleadings Saludares and Datu argued the RTC lacked jurisdiction over labor matters and the enforcement of NLRC writs because such matters fall within the NLRC’s exclusive competence; Manuel et al. intervened and moved to dismiss. By ...(Pro-only)
Issues:
- Did the Regional Trial Court have jurisdiction to enjoin the enforcement of the NLRC's Alias Partial Writ of Execution issued in favor of Josephine Manuel et al.?
- Did NEA’s filing of a third-party claim and a Motion to Quash with the NLRC constitute forum-shopping or otherwise submit NEA to the jurisdiction of the NLRC, thereby prec...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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