Aldovino v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners Gaudencio A. Aldovino and Anacleto G. Pimentel were regular employees of Atlantic Gulf and Pacific Company of Manila, Inc. (AG & P). Due to severe financial losses, AG & P implemented emergency measures, including temporary layoffs. The employees' union, petitioner United Rank and File Association (URFA), filed a notice of strike. An agreement was reached on September 7, 1991, between AG & P and its unions, including URFA, outlining financial assistance for laid-off employees. Aldovino and Pimentel were served notices of temporary layoff on September 17, 1991, and received financial assistance. Voluntary Arbitrator Romeo B. Batino upheld AG & P's right to temporarily lay off employees on January 7, 1992, finding the company's claim of financial losses substantiated. Pimentel was rehired on February 9, 1993, as a project employee at a reduced salary. Procedural History: In 1994, Aldovino and Pimentel filed separate complaints against AG & P for unfair labor practice, illegal layoff, illegal dismissal, and non-payment of CBA increases and benefits, praying for reinstatement with back wages and other benefits. The cases were consolidated. Labor Arbiter Ernesto S. Dinopol ruled in favor of Aldovino and Pimentel, finding them illegally dismissed and ordering reinstatement with back wages and attorney's fees, but rejecting the unfair labor practice charge and other monetary claims. AG & P appealed to the National Labor Relations Commission (NLRC), arguing that the validity of the temporary layoff was already decided by a voluntary arbitrator, thus constituting res judicata. Aldovino and Pimentel also appealed, questioning the computation of back wages and the denial of CBA increases. The Petition: The NLRC set aside the Labor Arbiter's decision, agreeing with AG & P that res judicata applied, citing the decision of Voluntary Arbitrator Batino and a prior NLRC decision in Revidad v. AG & P of Manila. The NLRC denied reconsideration. Petitioners filed a petition for certiorari with the Supreme Court, arguing that res judicata was inapplicable due to lack of identity of parties, subject matter, and causes of action, and that the extended layoff constituted constructive dismissal.
Issue(s)
Whether the principle of res judicata applies to the case, considering the prior decision of the voluntary arbitrator. Whether the requisites for res judicata, specifically the identity of parties are present. Whether the requisites for res judicata, specifically the identity of subject matter and causes of action are present; and whether the extended temporary layoff of petitioners constituted illegal dismissal. Whether the NLRC committed grave abuse of discretion in applying the principle of res judicata.
Ruling
The petition is dismissed. The Resolutions of the National Labor Relations Commission dated February 18, 1995, and March 30, 1995, are affirmed.
Ratio Decidendi
On the applicability of res judicata: The Court held that res judicata applies to decisions of voluntary arbitrators. For res judicata to attach, four requisites must be met: (a) the former judgment must be final; (b) the court rendering it had jurisdiction over the subject matter and parties; (c) it must be a judgment on the merits; and (d) there must be identity of parties, subject matter, and causes of action between the first and second actions. The Court found that these requisites were met in this case, thereby barring the relitigation of the validity of the temporary layoffs. On the identity of parties: The Court found that the identity of parties was satisfied. Although the prior voluntary arbitration case involved the union (URFA) and AG & P, the petitioners Aldovino and Pimentel were bona fide members of URFA at the time. The Court cited Davao Free Workers Front v. Court of Industrial Relations and Philippine Land-Air-Sea Labor Union (PLASLU), Inc. v. CIR, ruling that a labor union can represent its members, and individual members are bound by the union's actions unless they expressly withdraw from the case. Since Aldovino and Pimentel did not show they withdrew from the voluntary arbitration case, they were bound by its outcome. The Court reiterated that substantial identity of parties, including privity, is sufficient. On the identity of subject matter and causes of action, and the extended layoff constituting illegal dismissal: The Court found identity of subject matter and causes of action, referencing its ruling in Revidad v. NLRC. The Court reasoned that the voluntary arbitration proceeding under Arbitrator Batino did not solely concern the initial layoff but encompassed the continuing process of temporary layoffs implemented by AG & P due to financial reverses, as evidenced by the agreement signed on September 7, 1991, which both Aldovino and Pimentel availed of. The decision of Voluntary Arbitrator Batino, which attained finality due to no appeal, became the "law of the case." Allowing Aldovino and Pimentel to relitigate the validity of their layoffs would mean relitigating the reasonableness of AG & P's retrenchment program, a matter already settled. The Court concluded that the petitioners were barred by prior judgment from raising the issue of illegal dismissal due to the extended layoff. The test for identity of causes of action is whether the same evidence would sustain both actions. Relitigating the legality of the extended layoff would require re-examining the validity of the retrenchment program, which had already been adjudicated. The principle of interest republicae ut finis litium (it is in the interest of the public that there be an end to litigation) was invoked. On the NLRC's application of res judicata: The Court found no grave abuse of discretion on the part of the NLRC in applying the principle of res judicata. Given that the NLRC's application of res judicata was upheld, all other arguments raised by the petitioners became academic and did not require further resolution. The fact that both petitioners received separation pay and Pimentel was rehired further diminished the remaining issues.
Main Doctrine
The principle of res judicata applies to decisions of voluntary arbitrators, barring relitigation of issues already decided between the same parties or their privies, provided the requisites of res judicata are met, including identity of parties, subject matter, and causes of action.