Hawaiian Philippine Company v. Borra
REITERATIONFacts
The Antecedents: Private respondents filed a complaint for confirmation as regular employees against petitioner Hawaiian Philippine Company. Petitioner moved to dismiss, citing a prior judgment in 'Humphrey Perez, et al., vs. Jose Castillon, Hawaiian Philippine Company, et al.' (RAB Case No. 06-04-10169-95), where the Labor Arbiter held contractor Jose Castillon liable but absolved petitioner, finding no employer-employee relationship based on the absence of privity between petitioner and respondents during the period covered (1987-1995) when Castillon was the contractor. Procedural History: The Labor Arbiter granted petitioner's motion to dismiss. The NLRC reversed this, holding the two cases distinct. The Court of Appeals affirmed the NLRC's decision. The instant petition for review on certiorari assails the appellate court's affirmance. The Petition: Petitioner seeks to set aside the decision of the Court of Appeals which affirmed the NLRC's decision remanding the case to the Labor Arbiter for further proceedings.
Issue(s)
Whether the prior judgment in Perez vs. Castillon bars the present complaint for confirmation of regular employment based on res judicata and distinct causes of action. Whether the Court of Appeals committed reversible error in affirming the NLRC's decision, specifically regarding errors of law.
Ruling
The petition is DENIED, and the assailed decision of the Court of Appeals is AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the issue of res judicata and distinct causes of action: The Court held that the two cases involved different causes of action and periods. The previous case, 'Humphrey Perez, et al., vs. Jose Castillon, Hawaiian Philippine Company, et al.,' concerned a money claim for the period from 1987 up to 1995, during which private respondents were engaged by contractor Jose Castillon to work for petitioner. The Labor Arbiter's finding of no employer-employee relationship in that case was largely predicated on the absence of privity between petitioner and private respondents during that specific period and with that specific contractor. In contrast, the instant complaint for confirmation of employment was filed on September 12, 1997, by which time Jose Castillon was no longer the contractor. The contractor involved was Fela Contractor, and the prayer was for confirmation of their status as regular employees of petitioner. Therefore, the previous case pertained to employment from 1987 to 1995, while the instant case covered a different, subsequent period. The Court of Appeals correctly found that it was premature to conclude that the evidence in the Perez case would determine the outcome of the present case, as there was no showing that Fela Contractor was on the same footing as the previous contractor, Castillon, or that Fela Contractor merely stepped into Castillon's shoes. Factual issues regarding the nature of the relationship between petitioner and Fela Contractor, and whether Fela Contractor was a 'labor-only' contractor, needed to be ventilated first. The absence of privity in the previous case, which was the basis for absolving petitioner, was tied to the specific contractor and period involved then, and did not automatically extend to the new contractual arrangement with Fela Contractor. Consequently, the two cases involved different subject matters and causes of action, and the principle of res judicata did not apply to bar the present complaint. The Court reiterated that only errors of law, not of facts, are reviewable in a petition for review on certiorari under Rule 45, and found no reversible error in the appellate court's findings.
Main Doctrine
The Court of Appeals did not commit reversible error in affirming the NLRC's decision to remand the case to the Labor Arbiter for further proceedings, as the previous case involving a money claim and a different contractor did not bar the subsequent complaint for confirmation of regular employment due to distinct causes of action and periods covered.