Case Summary (G.R. No. 152343)
Proceedings Before the Labor Arbiter
On February 11, 1998, Domingo Arcega initiated a complaint for illegal dismissal against Viabel and Marlon Viado, which resulted in a favorable decision for Arcega on February 25, 1999. The Labor Arbiter determined the dismissal was illegal and ordered the payment of various monetary claims totaling P90,000 for back wages, P45,000 for separation pay, P5,192.40 for service incentive leave pay, P27,000 for 13th month pay, and P16,719.28 for attorney's fees. The claims for moral and exemplary damages were dismissed for lack of merit.
Finality of the Labor Arbiter's Decision
After the deadline for filing an appeal passed without action from Viabel or Viado, the decision of the Labor Arbiter became final and executory on May 21, 1999. Following this, the Labor Arbiter issued a writ of execution, leading to a sheriff's levy on June 8, 1999, of twenty-eight sewing machines belonging to Viabel for public auction scheduled on June 17, 1999.
Petitioner's Claim of Ownership
On June 17, 1999, Ma. Fe Bacos filed a notice of third-party claim asserting ownership of the levied machines, contending they were sold to her by Marlon Viado for P150,000, as evidenced by a Deed of Absolute Sale dated January 26, 1998. She contested the levy and sought to assert her rights as the legitimate owner of the machines.
Respondent's Opposition
In response to Bacos' claim, Arcega filed an opposition asserting that her claim was frivolous and spurious. Labor Arbiter Daisy G. Cauton-Barcelona examined the evidence and found the Deed of Absolute Sale lacking in authenticity, leading to the dismissal of Bacos' claim on January 10, 2000.
Appeals Process
Bacos appealed the Labor Arbiter's dismissal to the National Labor Relations Commission (NLRC), which upheld the Labor Arbiter's decision in a Resolution dated August 31, 2000, and later denied her motion for reconsideration on February 1, 2001. Bacos subsequently filed a petition for certiorari with the Court of Appeals, raising the same issues concerning her right to the levied property.
Court of Appeals Decision
On November 9, 2001, the Court of Appeals dismissed Bacos' petition, ruling that she failed to substantiate her claim of ownership. The court assessed that the Deed of Absolute Sale was deemed spurious and that Bacos had insufficient evidence to support her claim, lacking critical documentation and testimony from the notary involved.
Statutory and Procedural Framework
Bacos argued that Section 16, Rule 39 of the 1997 Rules of Civil Procedure allowed her to establish her claim through an affidavit of title without the necessity of producing the original deed of ownership. The relevant rule
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Case Background
- The case involves a petition for review on certiorari filed by Ma. Fe Bacos against Domingo Arcega, stemming from a decision made by the Court of Appeals regarding a third-party claim.
- The original complaint was filed by Domingo Arcega against Viabel International Garments, Inc. for illegal dismissal and monetary claims, which was adjudicated by Labor Arbiter Daisy G. Cauton-Barcelona.
- The Labor Arbiter ruled in favor of Arcega, ordering the payment of back wages, separation pay, service incentive leave pay, 13th month pay, and attorney's fees.
Key Proceedings
- Following the Labor Arbiter's decision on February 25, 1999, which became final on May 21, 1999, a writ of execution was issued due to the failure of Viabel and Marlon Viado to appeal.
- On June 8, 1999, 28 sewing machines owned by Viabel were levied by the NLRC sheriff for public auction scheduled for June 17, 1999.
Third-Party Claim
- On June 17, 1999, Ma. Fe Bacos filed a notice of third-party claim, asserting ownership of the levied sewing machines, claiming they had been purchased from Marlon Viado for P150,000.
- Bacos presented a Deed of Absolute Sale notarized on January 26, 1998, as evidence of her claim.