Samahan Ng Mga Manggagawa Sa Firestone and Its 291 Members Listed In Annex A v. National Labor Relations Commission, Firestone Tire & Rubber Company of the Philippines and Associated Labor Union
REITERATIONFacts
1. The Antecedents: This case concerns the claim for reinstatement of 291 employees of Firestone Tire & Rubber Company. These employees had declared a strike in August 1971. Subsequently, on February 22, 1973, they entered into an amicable settlement with the company, which included receiving separation pay. More than three months after this settlement, the employees filed a complaint for unfair labor practice against their employer, seeking reinstatement. 2. Procedural History: The underlying dispute began with a strike in August 1971. After affiliating with the Associated Labor Union (ALU), the striking employees' unions requested ALU to negotiate with Firestone. Firestone's refusal led to unfair labor practice cases before the Court of Industrial Relations (CIR). A compromise settlement was reached on February 22, 1973, under the ad hoc National Labor Relations Commission (NLRC), which provided for separation pay and priority in rehiring, and stipulated the withdrawal of all related cases. Despite executing quitclaims upon receiving separation pay, the employees filed a new unfair labor practice complaint in June 1973. This complaint was dismissed by a Labor Arbiter and the NLRC, citing res judicata and estoppel. The petitioners appealed this dismissal. 3. The Petition: The 291 employees, through their petition for certiorari filed on June 14, 1980, assail the NLRC's affirmation of the Labor Arbiter's dismissal of their unfair labor practice complaint. They argue that they lost their jobs after being pressured to accept separation pay instead of being reinstated. The petitioners contend that the compromise settlement was invalid or that they were not properly reinstated as per its terms. They seek to overturn the decisions of the lower labor tribunals and obtain their reinstatement.
Issue(s)
Whether the compromise agreement entered into by the ALU and Firestone, approved by the ad hoc NLRC, is binding on the 291 employees. Whether the employees are barred by res judicata and estoppel from claiming reinstatement after accepting separation pay and executing quitclaims pursuant to the compromise agreement. Whether the dismissal of the unfair labor practice complaint by the Labor Arbiter and the NLRC was proper.
Ruling
The petition is dismissed for lack of merit. The compromise agreement is binding on the petitioners, and their claims are barred by res judicata and estoppel. Reinstatement is not conducive to industrial peace.
Ratio Decidendi
On the binding nature of the compromise agreement: The ALU acted within its authority in negotiating the compromise settlement. This settlement was approved by the ad hoc National Labor Relations Commission (NLRC) and subsequently upheld by this Court in a related case (G.R. No. L-34390). The 291 petitioners availed themselves of the benefits of this compromise by receiving their separation pay and executing release or quitclaims. Therefore, they are bound by its terms and cannot subsequently assail it to claim reinstatement. On res judicata and estoppel: The compromise agreement, having been approved by the NLRC and upheld by the Supreme Court, effectively resolved all claims arising from the strike and employment termination. The petitioners' acceptance of separation pay and execution of quitclaims, which explicitly stated they had no further claims, created a binding settlement. To allow them to pursue reinstatement after accepting the benefits of the compromise would violate the principles of res judicata, as the matter has been judicially settled, and estoppel, as they are precluded from asserting a right contrary to their previous actions and representations. On the propriety of the dismissal of the complaint: The Labor Arbiter and the NLRC correctly dismissed the complaint for unfair labor practice. Their reliance on res judicata and estoppel was well-founded, given the existence of a valid and binding compromise agreement that had been approved by the NLRC and implicitly recognized by the Supreme Court. The subsequent filing of the complaint was an attempt to relitigate issues already settled by the compromise. The Court noted that at this late hour and under the circumstances, reinstatement would not be conducive to industrial peace or serve the ends of security of tenure and social justice.
Main Doctrine
A compromise agreement entered into by a union and an employer, which has been approved by the National Labor Relations Commission and subsequently upheld by the Supreme Court, is binding on the union members who availed themselves of its benefits, barring subsequent claims for reinstatement based on unfair labor practice.