Case Digest: NATIONAL ELECTRIFICATION ADMINISTRATION (NEA) v. HONORABLE FELICIANO V. BUENAVENTURA et al.

NATIONAL ELECTRIFICATION ADMINISTRATION (NEA) v. HONORABLE FELICIANO V. BUENAVENTURA et al.

           Because of serious institutional problems brought about by failure to pay maturing bills, National Electrification Administration (NEA) extended loans to Nueva Ecija III Electric Cooperative, Inc. (NEECO III). Consequently, the latter mortgaged its entire electric system or entire property to NEA. When NEECO III failed to pay its amortizations, NEA took over the properties and assets of the dissolved NEECO III.

            Meanwhile, former employees of NEECO III subsequently filed complaints against NEECO III for illegal dismissal, reinstatement, non-payment of salaries /backwages, 13th month pay, differentials, and bonuses. The Labor Arbiter ruled in favor of the dismissed employees and ordered NEECO III to immediately reinstate them with full payment of backwages and other damages. They subsequently filed before the NLRC an Ex Parte Motion for Alias Writ of Execution to collect the amount representing the award. NEECO III failed to comply with the order. The Regional Trial Court thereafter issued an order for the Sheriff to auction movable or immovable properties of NEECO until the award is satisfied.

              NEA assailed before the Regional Trial Court (RTC) of Cabanatuan City the Alias Writ of Execution. RTC denied the Motion on the ground that the trial court is powerless to restrain the Labor Arbiter whose decision became final and executory.

ISSUE:

Whether or not RTC has jurisdiction to enjoin NLRC and its labor arbiters from enforcing judgment or order regarding actions involving labor disputes

HELD:

The petition must be dismissed outright on the ground of lack of jurisdiction. It is the NLRC, not the RTC, which has jurisdiction over NEA’s move for the quashal of the Alias Partial Writ of Execution. Ostensibly the complaint before the trial court was for the recovery of possession and injunction, but in essence it was an action challenging the legality or propriety of the levy vis-à-vis the alias writ of execution, including the acts performed by the Labor Arbiter and the Deputy Sheriff implementing the writ. The complaint was in effect a motion to quash the writ of execution of a decision rendered on a case properly within the jurisdiction of the Labor Arbiter.

In case of failure to collect the said amount in cash, you are hereby directed to cause the full satisfaction of the same from the movable or immovable properties of NEECO III is not exempt from execution in accordance with the provision[s] of the Labor Code of the Philippines and the New Rules of Court.

Precedents abound confirming the rule that said courts have no jurisdiction to act on labor cases or various incidents arising therefrom, including the execution of decisions, awards, or orders. Jurisdiction to try and adjudicate such cases pertains exclusively to the proper labor official concerned under the Department of Labor and Employment.

Jurisdiction to try and adjudicate cases regarding labor disputes pertains exclusively to the proper labor official concerned under the Department of Labor and Employment. To hold otherwise is to sanction split jurisdiction which is obnoxious to the orderly administration of justice. NEA’s argument that the NLRC acquired no jurisdiction over it does not persuade.