Republic Bank v. Macaraeg
REITERATIONFacts
The Antecedents: Narciso Macaraeg (Macaraeg) filed an action for overtime pay against Republic Bank (Bank) in the Court of Industrial Relations (CIR), docketed as Case No. 1104-V. The CIR dismissed the case for lack of jurisdiction, but the CIR en banc set aside the dismissal. This Court, in G.R. No. L-16637, held that the CIR was without jurisdiction as the action was purely a money claim cognizable by ordinary courts, and set aside the CIR en banc resolution 'without prejudice to the filing of the claim of Macaraeg in any competent court.' Procedural History: Subsequently, Macaraeg filed another complaint in the CIR (Case No. 1538-V) for overtime pay, this time including a demand for reinstatement. This was filed during the pendency of another CIR case (Case No. 1751-ULP) where Macaraeg was a complainant for unfair labor practice with a demand for reinstatement and backwages. The Bank pleaded res judicata and moved to dismiss Case No. 1538-V. The trial judge sustained the plea and dismissed the case. However, upon motion for reconsideration, the CIR en banc set aside the dismissal, stating that res judicata was not applicable because the prior dismissal by the Supreme Court was not a conclusive adjudication on the merits, having been made 'without prejudice.' The Bank then filed the instant petition for review. The Petition: The Republic Bank seeks to set aside the resolution of the CIR en banc which gave due course to Macaraeg's complaint for overtime pay and reinstatement, arguing that the doctrine of res judicata should apply.
Issue(s)
Whether the prior ruling of the Supreme Court in G.R. No. L-16637 regarding the lack of jurisdiction of the Court of Industrial Relations (CIR) constitutes res judicata, barring the refiling of the same overtime claim in the CIR even with an added prayer for reinstatement.
Ruling
The Supreme Court set aside the resolution of the Court of Industrial Relations en banc dated February 8, 1963, and ordered the dismissal of the complaint. The Court ruled that the prior decision in G.R. No. L-16637, which declared the CIR without jurisdiction over the overtime pay claim, was a final adjudication on the merits concerning the issue of jurisdiction for a pure money claim. The subsequent inclusion of a prayer for reinstatement was deemed an attempt to circumvent the established jurisdiction and was also problematic as reinstatement was already the subject of another pending case.
Ratio Decidendi
On Issue 1: The Supreme Court held that its prior decision in G.R. No. L-16637 was an adjudication on the merits specifically regarding the issue of jurisdiction. The Court clarified that the phrase "without prejudice" meant that the substantive money claim was not barred from being filed in a competent court, which in this instance was the ordinary courts of justice as provided by Republic Act (RA) No. 602. The attempt by the respondent to manifest a pending reinstatement claim during the first case was rejected because it would have changed the cause of action, and that rejection attained finality. By filing Case No. 1538-V with a prayer for reinstatement, the respondent was attempting to circumvent the final determination that the CIR was the wrong forum for his overtime pay claim. The Court emphasized that the issue of reinstatement was already the subject of another separate action (Case No. 1751-ULP), which had in fact already been decided by the CIR. Consequently, the respondent could not use a pending issue from a different case to create jurisdiction for a claim that the Supreme Court had already directed to the ordinary courts.
Main Doctrine
A prior dismissal of a claim for overtime pay by the Supreme Court for lack of jurisdiction, which was explicitly stated to be 'without prejudice to the filing of the claim in any competent court,' does not constitute res judicata that would bar a subsequent filing of the same claim, especially when the subsequent filing includes a prayer for reinstatement, which may alter the nature of the claim and the jurisdiction of the court.