Philippine Coal Miner's Union v. Cebu Portland Cement
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns claims for overtime pay and additional compensation for work performed on Sundays, holidays, and Saturdays by employees and laborers of the Cebu Portland Cement Company (CEPOC), specifically those at the Malangas Coal Mines. The initial petition in 1948 by the Philippine Land-Air-Sea Labor Union (PLASLU) sought various labor demands, including adherence to the eight-hour labor law and increased salaries, which resulted in a favorable judgment on April 27, 1951. 2. Procedural History: Following the 1951 judgment, PLASLU sought to extend its benefits to employees in various CEPOC branches, including Malangas. A subsequent petition in 1959 by the Philippine Coal Miner's Union (PCMU), representing Malangas employees, demanded overtime pay and compensation under Republic Act No. 1880. The Court of Industrial Relations (CIR) initially ordered CEPOC to pay P112,762.30 for overtime services. However, the CIR en banc partially reconsidered, excluding the award for services rendered from July 1, 1951, to December 31, 1955, citing res judicata based on the earlier Case No. 241-V. 3. The Petition: The Philippine Coal Miner's Union (PCMU) filed a petition for certiorari with the Supreme Court, challenging the CIR en banc's resolution that excluded the P112,762.30 award. The PCMU argued that res judicata was not properly pleaded by CEPOC and that, in any event, no prior final judgment existed that barred the current claim. The Supreme Court was asked to reinstate the trial court's award and to rule on the applicability of res judicata and the identity of parties and subject matter between the two cases.
Issue(s)
Whether res judicata was properly alleged as a defense by the respondent. Whether res judicata exists under the facts and circumstances of the case, specifically concerning the award of overtime pay. Whether the resolution of the CIR en banc excluding the award of P112,762.20 was proper.
Ruling
The petition for certiorari is granted. The resolution of the respondent Court en banc dated July 19, 1961, is reversed insofar as it excluded the award of P112,762.20 contained in the trial court's decision dated June 20, 1960. Costs against the respondent Cebu Portland Cement Company.
Ratio Decidendi
On the issue of whether res judicata was properly alleged as a defense: The Supreme Court held that the defense of res judicata was not properly alleged by the respondent (CEPOC). The respondent's answer dated March 13, 1959, did not explicitly interpose the special defense of res judicata. Instead, it raised four affirmative defenses: lack of jurisdiction, prescription, payment, and that petitioners were not entitled to the relief prayed for. The Court found that the general allegation "petitioners are not entitled to the relief prayed for" is vague and not specific, failing to meet the requirement that grounds of defense must be specifically pleaded. Therefore, the respondent was deemed to have waived the defense of res judicata, as it was not pleaded in a motion to dismiss or in its answer, and could not be raised for the first time at the trial or on appeal, except for specific exceptions not applicable here. On the issue of whether res judicata exists under the facts and circumstances: Even granting that the averment could be considered a sufficient allegation of res judicata, the Court found that factually, there was no prior final judgment to speak of. The order of November 3, 1959, in Case No. 241-V, which the trial court considered a final judgment barring the present action, was deemed interlocutory by the Supreme Court. This order was aimed at giving parties a chance to adduce evidence and required them to perform certain acts for final adjudication of awards, such as the existence of bona fide employees and the nature of their claims. It was not an order or judgment determinative of a factual issue. Furthermore, the Court noted that the trial court itself, in its comment on the motion for reconsideration, indicated that matters could be taken up in a hearing after the examiner submitted his report, implying the order was not final. The order might even be considered void as the court that issued it may have lost jurisdiction after the filing of the "notice to terminate the award" on July 11, 1956, rendering the decision of April 27, 1951, without force and effect. Thus, no basic right of the workers for overtime pay was decided in that order. On the issue of identity of parties, subject matter, and cause of action: The Court found no identity of parties, subject matter, and cause of action between Case No. 241-V and the present Case No. 6-V-Davao. Case No. 241-V was filed by PLASLU against CEPOC concerning demands for concessions for employees at CEPOC's plant in Naga, Cebu, decided on April 27, 1951. The subsequent incident in October 1956 sought to extend these benefits to other branches. In contrast, Case No. 6-V-Davao was an independent action filed by PCMU, a separate union, on behalf of employees exclusively at the Malangas Coal Mines, seeking overtime pay and implementation of R.A. 1880 for services rendered from 1951 onwards. The Malangas Coal Mines became a unit of CEPOC in 1951, and PCMU was organized in 1958. The present suit was an independent action by a distinct union composed of members exclusively employed at Malangas, who were not shown to be members of PLASLU. Therefore, the principle of res judicata did not apply.
Main Doctrine
The defense of res judicata must be specifically pleaded and cannot be raised for the first time on appeal, and an interlocutory order, which requires parties to perform certain acts for final adjudication, does not constitute a final judgment that can give rise to res judicata.