Pacific Mills, Inc. vs. National Labor Relations Commission and/or City Sheriff of Manila

Execution of a final judgment of the NLRC may be stayed where supervening events affect the computation of the award; the NLRC has the duty to consider such events and inquire into the correctness of the execution, and its refusal to do so constitutes grave abuse of discretion.

Pacific Mills, Inc. was the petitioner in the present case and the respondent company in the labor case below, while the private respondents were the complainants in that case. The NLRC decision in that case became final after this Court dismissed Pacific Mills’ prior petition in G.R. No. 79535 on August 3, 1988 for failure to sufficiently show grave abuse of discretion.

Pacific Mills, Inc. was the petitioner in a labor case that had reached the NLRC. In G.R. No. 79535, on August 3, 1988, the Supreme Court dismissed Pacific Mills’ petition questioning the NLRC decision for failure to sufficiently show grave abuse of discretion. Entry of judgment was thereafter effected. In the process of executing the labor arbiter’s decision, the NLRC computed the award to the private respondents at P680,037.30 on April 28, 1989. On May 5, 1989, the NLRC issued a partial writ of execution for P655,527.30.

On May 9, 1989, Pacific Mills filed a motion to stay execution/reconsideration, citing supervening events that affected the computation of the award: (a) the computation of separation pay did not consider the length of service of each complainant as borne out by the records; (b) the computation did not consider the wage exemptions granted to petitioner; (c) the computation included payment of awards to a respondent who had already been recalled to active duty, one who was already paid in a case separately filed, and another who was already paid regardless of the result of the case docketed G.R. No. 79535; and (d) all the capital assets of petitioner had already been attached by Philippine Cotton Corp. and/or otherwise foreclosed by the Development Bank of the Philippines in appropriate proceedings.

On June 21, 1989, the NLRC did not stay execution of judgment and issued an order for immediate implementation of the partial writ of execution without further delay. Pacific Mills then filed the present petition, alleging that the NLRC committed grave abuse of discretion in issuing the two questioned orders.

• Grave Abuse of Discretion: Petitioner alleged that the NLRC committed grave abuse of discretion in issuing the May 5, 1989 partial writ of execution and the June 21, 1989 order for immediate implementation.
• Supervening Events Affecting Computation: Petitioner moved to stay execution/reconsideration, citing supervening events that affected the computation: the separation pay computation did not consider each complainant’s length of service; the computation did not consider wage exemptions granted to petitioner; and the computation included awards to a respondent already recalled to active duty, one already paid in a separately filed case, and another already paid regardless of the result of G.R. No. 79535.
• Attachment/Foreclosure of Assets: Petitioner also cited that all its capital assets had already been attached by Philippine Cotton Corp. and/or foreclosed by the Development Bank of the Philippines in appropriate proceedings.

• Failure to Raise Objections: Public respondent alleged that in several conferences with petitioner, petitioner did not raise these objections.
• Dilatory Petition: Public respondent alleged that the petition is dilatory.

• Stay of Execution Due to Supervening Events: Whether the execution of a final judgment of the NLRC may be stayed in view of supervening events.

• Stay of Execution Due to Supervening Events: Yes. Execution may be stayed where supervening events affect the computation of the award; the NLRC must consider them and inquire into the correctness of the execution. Denial of that opportunity constitutes grave abuse of discretion.

• Stay of Execution Due to Supervening Events: The supervening events cited—length of service, wage exemptions, and payments already made—would certainly affect the computation of the total award. It is the duty of the NLRC to consider such events and inquire into the correctness of the execution. Although public respondent alleged that petitioner did not raise these objections in conferences and that the petition was dilatory, those allegations did not negate the fact that the events affected the computation. A prompt determination of the objections and recomputation of the award should be made; denial of the opportunity to right a clear error in execution constitutes grave abuse of discretion. The Court cited Abbot vs. National Labor Relations Commission, 145 SCRA 206 (1986).

• Supervening Events in Execution of Final Judgment — A final judgment’s execution may be stayed or corrected where supervening events materially affect the computation of the award. The NLRC has the duty to consider supervening events and inquire into the correctness of execution. If such events affect the computation, a prompt determination and recomputation should be made. Denial of the opportunity to right a clear error in execution constitutes grave abuse of discretion.
• Grave Abuse of Discretion — A denial of the opportunity to right a clear error in the execution of a judgment constitutes grave abuse of discretion.

• "The only issue in this petition is whether the execution of a final judgment of the National Labor Relations Commission (NLRC) may be stayed in view of supervening events." — States the sole issue framed by the Court.
• "There can be no question that the supervening events cited by petitioner would certainly affect the computation of the award in the decision of the NLRC." — Articulates the core factual premise for allowing the stay or correction of execution.
• "It is the duty of the NLRC to consider the same and inquire into the correctness of the execution, as such supervening events may affect such execution." — States the NLRC’s affirmative duty when supervening events are raised.
• "A denial of this opportunity to right a clear error in the execution of the judgment constitutes a grave abuse of discretion." — Supplies the ratio for granting the petition.

• Abbot vs. National Labor Relations Commission, 145 SCRA 206 (1986) — Cited in footnote as authority for the duty of the NLRC to consider supervening events and inquire into the correctness of execution.
• Pacific Mills, Inc. vs. National Labor Relations Commission, et al., G.R. No. 79535, August 3, 1988 — Prior related case in which this Court dismissed Pacific Mills’ petition for failure to sufficiently show grave abuse of discretion; entry of judgment was effected, making the NLRC decision final and executory.

Narvaza, Cruz, Griño-Aquino, and Medialdea, JJ., concurred.