Gonzales v. Secretary of Labor
REITERATIONFacts
1. The Antecedents: Petitioners, employees of Philippine Business Forms, Inc. and members of a labor union, went on strike on March 15, 1965, due to alleged unfair labor practices by the company, including illegal dismissal, withholding of union dues, refusal to bargain, and interference with self-organization rights. The company filed a countercharge alleging the strike was illegal and constituted restraint or coercion of employees. The petitioners offered to return to work on March 31, 1965, but were refused. Subsequently, Philippine Business Forms, Inc. sold its printing business and equipment in October 1968 and later changed its name to Belisle Investment and Financing Corporation. 2. Procedural History: The Court of Industrial Relations (CIR) dismissed the union's unfair labor practice charge (Charge No. 446-ULP) on February 5, 1969, for failure to establish a prima facie case, and the company's countercharge (Charge No. 466-ULP) on September 18, 1969. The petitioners again offered to return to work on March 30, 1971, and were refused, leading them to file a complaint for reinstatement with back wages (Charge No. 4327) with the CIR. Following the issuance of Presidential Decree No. 21, the case was transferred to the Ad Hoc National Labor Relations Commission (NLRC) as NLRC (Ad Hoc) Case No. 0385. This case was dismissed on January 18, 1973, on the grounds of res adjudicata, a decision affirmed by the Secretary of Labor. Meanwhile, CIR Case No. 6065-ULP was filed and subsequently transferred to the NLRC, where it was again dismissed on the grounds of res adjudicata. This dismissal was affirmed by the Secretary of Labor on June 8, 1978. 3. The Petition: The petitioners seek review of the Secretary of Labor's decision affirming the dismissal of their complaint for reinstatement with back wages in NLRC Case No. 6065-ULP. They contend that res adjudicata does not apply because NLRC (Ad Hoc) Case No. 0385 was not decided on the merits and that the causes of action in the two cases were not identical. The Supreme Court, however, found no merit in the petition, agreeing with the Secretary of Labor that the action was barred by the prior judgment in NLRC (Ad Hoc) Case No. 0385 due to the identity of parties, subject matter, and cause of action. The Court held that the dismissal of NLRC (Ad Hoc) Case No. 0385 was a valid judgment on the merits, even if based on a finding of res adjudicata, and that the issue of reinstatement with back wages was therefore res adjudicata.
Issue(s)
Whether the complaint for reinstatement with back wages in NLRC Case No. 6065-ULP is barred by prior judgment (res adjudicata) due to the dismissal of NLRC Ad Hoc Case No. 0385. Whether NLRC Ad Hoc Case No. 0385 was decided on the merits. Whether the causes of action in NLRC Ad Hoc Case No. 0385 and NLRC Case No. 6065-ULP are identical.
Ruling
The petition is denied. The Supreme Court affirmed the dismissal of the complaint for reinstatement with back wages on the ground that the action is barred by prior judgment (res adjudicata).
Ratio Decidendi
On the issue of res adjudicata: The Court found no merit in the petition and agreed with the Secretary of Labor that the action was barred by prior judgment. There was an identity of parties, subject matter, and cause of action between NLRC Ad Hoc Case No. 0385 and NLRC Case No. 6065-ULP. The Ad Hoc NLRC had jurisdiction over the complaint, and its dismissal was regular on its face, not tainted with fraud. If the dismissal was erroneous, petitioners should have appealed to the Supreme Court, but since they did not, the order became final and executory and could not be collaterally attacked. Therefore, the issue of reinstatement with back wages was res adjudicata. On whether NLRC Ad Hoc Case No. 0385 was decided on the merits: The Court held that the contention that the decision was not on the merits was without merit. Although the case was dismissed on the ground of res adjudicata, the issue of reinstatement with back wages was raised by the petitioners, making the dismissal a judgment on the merits. The Mediation Fact Finding Report clearly outlined the issue of illegal dismissal and the relief sought (reinstatement with back wages), and both parties presented their positions. The rule states that if both parties have been heard or had an opportunity to be heard, and the court dismisses the action, it is a judgment on the merits. On the identity of causes of action: The Court found the petitioners' claim of non-identical causes of action to be devoid of merit. The petitioners themselves stated that the cause of action in NLRC Ad Hoc Case No. 0385 was "Reinstatement and backwages due to illegal dismissal, 1971 when reinstatement was refused," while the cause of action in NLRC Case No. 6065-ULP was "Reinstatement with backwages due to illegal dismissal of the Complainant - strikers." The allegations in the complaint for NLRC Case No. 6065-ULP explicitly mentioned the unconditional offer to return to work made on May 31, 1965, and reiterated on March 30, 1971, which was denied by the respondent. This clearly shows that the cause of action was the alleged refusal of respondents to reinstate them, which was the same basis for the earlier complaint. The complaint in NLRC Case No. 6065-ULP was merely a reiteration of the complaint filed in NLRC Ad Hoc Case No. 0385, which itself stemmed from the original charge filed with the CIR.
Main Doctrine
A case involving reinstatement with back wages is considered res adjudicata and no longer open for review if the cause of action was already the subject of prior dismissed cases with the same parties, subject matter, and cause of action, provided the prior dismissal was regular on its face and not tainted with fraud.