International Harvester Macleod, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents, Waterfront Employees Union (WEU) and its members, filed a complaint for illegal dismissal, separation pay, and 13th month pay against petitioner International Harvester Macleod, Inc. (IHM), a ship agent. They alleged that IHM hired them as checkers from 1950 to 1978, illegally terminated them in 1979, and that a checkers agency took over their functions. They claimed their cause of action accrued in 1982 after a Supreme Court resolution became final, arguing the prescriptive period was interrupted and doubts should favor labor. Procedural History: Labor Arbiter Alex Lopez ruled that private respondents were employees of IHM and that IHM was liable for illegal dismissal. The National Labor Relations Commission (NLRC) dismissed IHM's appeal. The present petition seeks to annul the NLRC resolutions. The Petition: Petitioner IHM argues that a prior Bureau of Labor Relations (BLR) ruling cited by the respondents was inapplicable as it arose after IHM terminated its contract with WEU and after some checkers were employed by another agency. IHM also contends the claims have prescribed, having been filed four years after the alleged dismissal.
Issue(s)
Whether the private respondents were employees of the petitioner IHM during the period relevant to their claims. Whether the claims for separation pay and 13th month pay have prescribed.
Ruling
The Court Resolved to GRANT DUE COURSE to the Petition for certiorari and to SET ASIDE and ANNUL the Resolutions of public respondents NLRC in NLRC Case No. 12-4388-84 dated 24 August 1988 and 12 December 1988. Costs against private respondents.
Ratio Decidendi
On the issue of employer-employee relationship: The Court examined two prior Supreme Court rulings involving the same parties. In G.R. No. 51311, the Court affirmed a Deputy Minister of Labor's decision that WEU was an independent contractor and the employer of the checkers, not IHM. This ruling was based on the factual circumstances during the period when the "Collective Bargaining Agreements" were in effect, from at least 1977 up to December 31, 1979. The Court found that under that arrangement, IHM did not individually employ the checkers, did not control their assignments, and the union treasurer prepared the payroll, with IHM merely facilitating the payment from client shipowners. The Court held that this ruling in G.R. No. 51311 was res judicata for the present case, as the claims of private respondents arose from the period covered by that ruling. The subsequent ruling in G.R. No. 57880, which involved factual relationships established after December 31, 1979, and the engagement of a new checker agency, was deemed not to have overruled or set aside the earlier decision. Therefore, during the period relevant to the claims (prior to December 31, 1979), no employer-employee relationship existed between IHM and the checkers. On the issue of prescription: The Court noted that the case for alleged illegal dismissal was filed almost exactly five (5) years after it allegedly took place at the end of 1979. Article 291 of the Labor Code establishes a three-year prescriptive period for money claims arising from employer-employee relations. Since the claims were filed beyond this period, they were barred by prescription. The Court also observed that the filing of the case appeared to be a mere afterthought, possibly encouraged by the later Supreme Court resolution in G.R. No. 57880, but that private respondents were attempting to re-litigate issues already settled in G.R. No. 51311, which is impermissible.
Main Doctrine
Where prior Supreme Court rulings have definitively established the absence of an employer-employee relationship between parties based on specific factual circumstances existing during a particular period, subsequent claims arising from that same period must adhere to those prior rulings, even if later factual circumstances involving the same parties led to a different determination. Claims filed beyond the prescriptive period are also barred.