Elizalde Special Police Union v. Office of the President
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from the dismissal of 180 security employees by Elizalde & Co., Inc. on February 28, 1974, following the closure of its security department. The Elizalde Special Police Union (petitioner) filed a complaint for illegal dismissal, asserting the dismissals violated PD No. 21. Initially, the NLRC ordered reinstatement with backwages, a decision affirmed by the Secretary of Labor. The company's subsequent petition for certiorari to the Supreme Court (G.R. No. L-39097) was dismissed for lack of merit. 2. Procedural History: Following the initial Supreme Court dismissal, the parties entered into a compromise agreement. However, 25 union members challenged this agreement, leading to a Labor Arbiter's order declaring it invalid for them and mandating reinstatement with full backwages. This order was affirmed by the NLRC and the Secretary of Labor, though the latter modified it to six months' backpay and suspended reinstatement pending further determination. Both parties appealed: the 25 members to the Office of the President, and the company to the Supreme Court (G.R. No. L-43954), which was dismissed. The Office of the President affirmed the Secretary of Labor's order with modifications. The company then filed another petition with the Supreme Court (G.R. No. L-45450) to annul the Office of the President's decision, which was also dismissed, with the Court requiring the company's counsel to explain their actions. 3. The Petition: Despite the multiple dismissals of the company's petitions and the resolution of the Office of the President, the Elizalde Special Police Union filed the present petition (G.R. No. L-45498) with the Supreme Court. This petition assails the same decision issued by Presidential Assistant Ronald B. Zamora on October 20, 1976. The Solicitor General argues for outright dismissal, noting this is the fourth time the case has reached the Supreme Court and the second time this specific decision has been brought for review, emphasizing that the issues were already passed upon in G.R. No. L-45450.
Issue(s)
Whether the present petition raises issues already decided by this Honorable Court. Whether the filing of the present petition constitutes forum shopping.
Ruling
The petition is dismissed.
Ratio Decidendi
On Whether the present petition raises issues already decided by this Honorable Court: The Court noted that the present petition (G.R. No. L-45498) assails the decision of Presidential Assistant Zamora dated October 20, 1976. This same decision was previously the subject of a petition filed by the respondent company in G.R. No. L-45450. In G.R. No. L-45450, the Supreme Court had already passed upon the validity of the Zamora decision and dismissed the petition for lack of merit. The petitioner union was the private respondent in G.R. No. L-45450 and had been duly heard by the Court. Therefore, the issues raised in the present petition have already been decided by this Court. On Whether the filing of the present petition constitutes forum shopping: The Court found that the filing of the present petition by the union, assailing the same decision of Presidential Assistant Zamora that was already dismissed in G.R. No. L-45450, constituted an act of forum shopping. The Supreme Court explicitly stated in the resolution of G.R. No. L-45450 that the point at issue had been passed upon and found to be lacking in merit in a previous resolution. The subsequent filing of a petition by the union on the same matter, after the company's petition on the same matter was dismissed, demonstrates a pattern of seeking favorable rulings from different forums or repeatedly invoking the Court's jurisdiction on issues already resolved, which is contrary to the principle of judicial economy and the prohibition against forum shopping. The Court's resolution in G.R. No. L-45450 already required the lawyers for the company to explain why no disciplinary action should be taken against them for filing a petition when the issue had already been passed upon and found to be lacking in merit.
Main Doctrine
A petition that raises issues already passed upon and dismissed by the Supreme Court in a previous case involving the same parties and the same subject matter constitutes forum shopping and will be dismissed outright.