Facts:

The case involves Rizal Security & Protective Services, Inc. and Rufino S. Antonio, Jr. as petitioners against Director Alex E. Maraan, the Regional Sheriff of the Department of Labor and Employment (DOLE) in the Cordillera Administrative Region, along with several respondents who were formerly employed security guards of Rizal Security. The proceedings originated from a complaint filed on May 19, 1995, by private respondents Rico Gomez and Edwin Tupas, who sought assistance from DOLE regarding alleged violations of labor laws, including illegal wage deductions and non-payment of applicable benefits. An inspection was carried out on June 1, 1995, yielding multiple violations, including underpayment of wages and non-payment of overtime and other benefits.

As hearings proceeded, private respondents submitted their resignations effective September 1, 1995, coinciding with the termination of services notice from Rainbow End Village sent to Rizal Security. On January 24, 1996, DO

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Facts:

Parties Involved

• Petitioners:
• Rizal Security and Protective Services, Inc. – a corporation organized under Philippine laws operating as a security agency.
• Rufino S. Antonio, Jr. – President of Rizal Security.
• Respondents:
• Public Official – Alex E. Maraan, then DOLE-CAR Regional Director (later referred to as DOLE-CAR Director Maraan).
• Private Respondents – Former employees (security guards) of Rizal Security, including Rico Gomez, Edwin O. Tupas, Rolando Tupas, Detecio Vicente, Roberto Ruiz, Ronnie Llabres, Dennis Llabres, and Sandy Figer, among others.

Initiation of the Case

• On May 19, 1995, two private respondents (Rico Gomez and Edwin O. Tupas) filed a labor complaint (CAR00-9507-CI-25) with the DOLE-CAR Regional Office alleging:
• Illegal deduction of wages.
• Underpayment of night shift differential.
• Underpayment of minimum wage.
• Nonpayment of overtime pay, legal holiday pay, and 13th month pay.
• A labor inspection was conducted on June 1, 1995 by a DOLE inspector, which later resulted in a Notice of Inspection Results on October 9, 1995, citing multiple labor standard violations.

Significant Procedural Events

• Concurrent with the labor complaint, two pivotal events occurred:
• Private respondents, while still employed, submitted resignation letters on July 10, 1995, effective September 1, 1995.
• Rainbow End Village, where the guards were deployed, sent a Notice of Termination of Services on July 25, 1995, effective September 1, 1995.
• During a hearing on October 23, 1995, Rizal Security submitted a Manifestation and Motion challenging the jurisdiction of the DOLE-CAR Regional Office based on the claim that the employer-employee relationship had already been severed.
• On January 24, 1996, the DOLE-CAR Regional Office, through Director Maraan, issued an Order denying the motion and ordering Rizal Security to pay monetary deficiencies amounting to ₱560,989.70 for eight security guards, with detailed computation for each employee.

Subsequent Developments and Controversies

• Petitioners contended that they had not received an official copy of the January 24, 1996 Order. Their counsel secured a copy only on June 18, 1996, from the DOLE Regional Office.
• On May 8, 1996, petitioners’ counsel received the Writ of Execution dated March 12, 1996, ordering the Regional Sheriff to enforce the payment within ten days, despite arguments that proper notice was never effected.
• Petitioners sought a writ of certiorari and a Temporary Restraining Order (TRO) under Rule 65 to:
• Enjoin the execution of the January 24, 1996 Order and the subsequent Writ of Execution.
• Assert that the jurisdiction had shifted to the NLRC due to the employees’ resignation and that the DOLE-CAR Director had acted without or in excess of his jurisdiction.
• The petition initially faced dismissal for non-compliance with evidentiary requirements but was reinstated after a motion for reconsideration and proper compliance thereof.

Issue:

Jurisdiction of the DOLE-CAR Regional Office

• Whether the DOLE-CAR Director Maraan acted without or in excess of his jurisdiction in issuing the January 24, 1996 Order.
• Whether the fact that private respondents had resigned (effective September 1, 1995) should have ousted the jurisdiction of the DOLE-CAR Regional Office and transferred the case to the Labor Arbiter under NLRC.

Due Process and Notice Requirements

• Whether petitioners were deprived of due process by not receiving an official copy of the January 24, 1996 Order in a timely manner.
• Whether the failure in proper service of the notice vitiated the finality of the Order, rendering the subsequent Writ of Execution premature and without legal basis.

Appropriateness of the Issuance of the Writ of Execution

• Whether issuing the Writ of Execution on March 12, 1996, without proper notice and without affording petitioners a chance to contest the Order, amounted to a grave abuse of discretion.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)