Pagtakhan v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: This case concerns an unfair labor practice complaint filed by approximately forty-three employees of La Perla Cigar & Cigarette Factory, Inc. against the company and its manager. The employees, who were members of the Federacion Obreros de la Industria de Tabacos de Filipinas (FOITAF), alleged discriminatory practices by the company. These practices included preferential treatment of non-union members, attempts to persuade employees to switch unions, and ultimately, the refusal to rehire the complainants after their temporary assignments and the reopening of a burned branch where they were previously employed. Procedural History: The complaint was filed with the Court of Industrial Relations (CIR) in December 1962. After the employees presented their evidence, the respondents moved to dismiss the case, arguing lack of jurisdiction and laches. This motion was denied by the trial judge. The respondents then filed a motion for reconsideration of this denial. Despite the pending motion for reconsideration, the trial judge proceeded with hearings, but the respondents failed to appear. The trial judge subsequently issued an order on May 20, 1964, finding the company guilty of unfair labor practice and ordering reinstatement with back wages. The CIR en banc, however, set aside this order and remanded the case for further proceedings, including the reception of the respondents' evidence. The employees sought review of this en banc resolution. The Petition: The petitioners filed a petition for certiorari with the Supreme Court, challenging the CIR en banc's resolution of October 14, 1964. They argued that the CIR en banc erred in holding that the trial judge should have suspended proceedings upon the filing of a motion for reconsideration of an interlocutory order denying a motion to dismiss. The core issue presented to the Supreme Court was whether a motion for reconsideration of an interlocutory order, specifically an order denying a motion to dismiss based on a demurrer to the evidence, automatically suspends proceedings before a trial judge and elevates the matter to the CIR en banc for resolution.
Issue(s)
Whether or not the filing of a motion for reconsideration of an interlocutory order, such as a denial of a motion to dismiss (demurrer to evidence), automatically suspends the proceedings before a trial judge of the Court of Industrial Relations (CIR) or elevates the case to the CIR en banc.
Ruling
The Supreme Court reversed and set aside the resolution of the CIR en banc dated October 14, 1964, and declared the judgment of the trial judge embodied in his order of May 20, 1964, final and executory against the private respondents.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of Industrial Relations (CIR) en banc erred in ruling that a trial judge should suspend proceedings upon the filing of a motion for reconsideration of an interlocutory order, such as an order denying a motion to dismiss based on insufficiency of evidence (demurrer to evidence). The Court firmly reiterated the settled rule that an order denying a motion to dismiss is an interlocutory order and is not appealable, citing numerous precedents including Sitchon vs. Sheriff of Occidental Negros and PLDT Employees Union vs. PLDT Co. Free Tel. Workers Union. The rationale is to prevent multiplicity of appeals in a single action, which would unduly suspend the hearing and decision on the merits, compel the adverse party to incur unnecessary expenses, and delay the speedy disposition of cases. Under Section 1 of Commonwealth Act No. 103 (C.A. 103), a CIR judge, when designated to hear a case, acts as a trial judge and can decide the case with finality, unless their final order or decision is appealed to the CIR en banc. Therefore, only a final order or decision of the trial judge can be appealed to the CIR en banc, and it is this final appeal that may suspend the proceedings before the trial judge. To allow appeals from interlocutory orders, regardless of their nature, would open the door to parties interposing frivolous appeals purely for delay, a practice explicitly discouraged by public policy as established in cases like Harrison Foundry & Machinery vs. Harrison Foundry Workers Association. The Court concluded that the trial judge acted properly in proceeding with the case and deciding it based on the petitioners' evidence, especially since the respondents, having filed a demurrer to evidence, had the opportunity to present their own evidence after its denial but failed to appear for subsequent hearings.
Main Doctrine
An order denying a motion to dismiss, including a demurrer to the evidence, is interlocutory and not appealable. Filing a motion for reconsideration of such an order does not suspend proceedings before the trial court, nor does it automatically elevate the case to the Court en banc. Resorting to appeals from interlocutory orders for the purpose of delay is an abuse of process and will not be countenanced.