Title
Execution on fake surety bonds upheld
Law
Nlrc En Banc No. 05-13
Decision Date
Oct 9, 2013
The NLRC en banc resolution mandates that execution of final judgments in labor cases shall proceed despite claims of spurious surety bonds by bonding companies, prioritizing the welfare of workers and ensuring they receive their monetary awards.

Law Summary

Issue of Spurious or Fake Surety Bonds

  • There have been instances where bonding companies refuse payment, claiming that the surety bond posted is spurious or fake.
  • This refusal poses challenges to the enforcement of monetary awards in labor disputes.

Legal Position on Refusal Based on Spurious Bond Claims

  • The refusal to pay by a bonding company on the ground that the surety bond is fake does not:
    • Extinguish the company’s joint and solidary liability.
    • Suspend the execution proceedings against the bond.
  • The welfare of the workers is prioritized over technical defenses raised by bonding companies.

Procedural Directive Regarding Execution of Judgment

  • Execution of the final judgment against the surety bond shall proceed despite the bonding company’s refusal to pay on grounds of the bond’s alleged spuriousness.
  • Such execution may only be stayed if a higher court issues an injunction.

Signatories and Formal Adoption

  • The resolution was unanimously adopted by the National Labor Relations Commission (NLRC) En Banc on October 9, 2013.
  • It signifies the collective stance of commissioners and presiding officers on protecting workers’ rights concerning appeal bonds.

Implications for Labor Practice

  • This ruling reinforces the enforcement of labor awards despite disputes over the authenticity of surety bonds.
  • It emphasizes speedy and effective relief for workers, minimizing delays caused by bonding companies’ defenses.

Summary of Key Legal Concepts

  • Appeal bond: A security posted to guarantee payment of judgment awards in labor appeals.
  • Surety bond: The bond posted, typically by bonding companies, as financial security.
  • Solidary liability: Joint responsibility that ensures all liable parties are accountable.
  • Execution proceedings: Legal steps to enforce a court judgment.
  • Injunction: A court order to temporarily or permanently prevent a specific action, in this case, the execution of judgment.

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.