Malayang Samahan ng Manggagawa sa Balanced Food v. Pinakamasarap Corporation
REITERATIONFacts
The Antecedents: The underlying dispute arose when the Malayang Samahan ng Manggagawa sa Balanced Food, along with its officers and members, sought the ouster of the respondent company's Production Manager and Assistant Manager. The respondent company alleged that on March 13, 1993, approximately 200 to 206 union officers and members deliberately abandoned their work, picketed the premises, and subsequently engaged in illegal activities such as work slowdown and sabotage, severely disrupting operations. The company filed a complaint for unfair labor practices and damages, asserting violations of the Labor Code and the Collective Bargaining Agreement. Procedural History: The Labor Arbiter, on July 19, 1994, declared the forfeiture of employment status for fifteen union officers. This decision was appealed to the National Labor Relations Commission (NLRC), which, on August 25, 1995, upheld the illegality of the strike but ordered reinstatement. Motions for reconsideration were denied. Both parties filed petitions for certiorari with the Supreme Court; the company's petition (G.R. No. 123364) was dismissed for lack of a verified statement of material dates, and the union's petition (G.R. No. 123976) was dismissed on January 27, 1997, for failure to show grave abuse of discretion by the NLRC, becoming final on February 27, 1997. Subsequently, the Labor Arbiter issued a writ of execution for reinstatement. The respondent company appealed to the NLRC to quash the writ, but the NLRC held it was not appealable. An alias writ of execution was issued. The company again moved to recall it, citing supervening events, which the Arbiter granted. The NLRC set aside the Arbiter's order and remanded the case for implementation of the alias writ. The NLRC's denial of a motion for reconsideration led the company to file a petition for certiorari with the Supreme Court, which was referred to the Court of Appeals. The Petition: The present petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure assails the March 19, 1999 Decision and June 15, 1999 Resolution of the Court of Appeals. Petitioners argue that the Court of Appeals gravely abused its discretion by modifying the NLRC's final and executory decision. They contend that the appellate court, by declaring that petitioners lost their employment status, passed upon an issue already decided by this Court in G.R. No. 123976 and disregarded the doctrine of res judicata, which should have rendered the issue of reinstatement immutable and unalterable.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in modifying the final and executory Decision of the NLRC by declaring that the petitioners have lost their employment status. Whether the doctrine of res judicata applies to the issues already passed upon and decided by this Court in G.R. No. 123976.
Ruling
The petition is GRANTED. The assailed Decision dated March 19, 1999 and Resolution dated June 15, 1999 of the Court of Appeals in CA-G.R. SP No. 50186 are REVERSED and SET ASIDE. The Labor Arbiter is ordered to implement the alias writ of execution with dispatch.
Ratio Decidendi
On the issue of whether the Court of Appeals gravely abused its discretion in modifying the final and executory Decision of the NLRC by declaring that the petitioners have lost their employment status: The Court held that the Court of Appeals gravely abused its discretion. The NLRC's Decision dated August 25, 1995, which upheld the illegality of the strike but ordered reinstatement, had become final and executory. This finality was further reinforced by this Court's dismissal of both the respondent company's and the petitioners' petitions for certiorari in G.R. Nos. 123364 and 123976, respectively. The subsequent filing of a petition for certiorari by the respondent company with the Supreme Court, which was then referred to the Court of Appeals, should not have allowed the appellate court to revisit and modify a judgment that had already attained finality. The Court of Appeals' action in declaring that the petitioners had lost their employment status effectively disregarded the immutable nature of a final and executory judgment. The Court emphasized that once a judgment becomes final and executory, it can no longer be modified or altered in any respect, save for clerical errors or the correction of mistakes, which were not present in this case. The principle of res judicata mandates that issues that have been judicially tried and determined by a court of competent jurisdiction should be conclusive upon the parties and should not be relitigated. On the issue of whether the doctrine of res judicata applies to the issues already passed upon and decided by this Court in G.R. No. 123976: The Court unequivocally held that the doctrine of res judicata applies. The Court reiterated that res judicata is founded on public policy and the hardship on the individual of being vexed twice for the same cause. In this case, the issue of whether the petitioners should be reinstated to their former positions, despite the finding that they participated in an illegal strike or walkout, was already passed upon and decided by this Court in G.R. No. 123976. The dismissal of the petition in G.R. No. No. 123976, on the ground that no grave abuse of discretion could be attributed to the NLRC, meant that the NLRC's decision ordering reinstatement was affirmed as a final and executory judgment. Therefore, the Court of Appeals, in its subsequent decision, should not have revisited this matter, as it would constitute a violation of the principle of res judicata. The Court cited Stilianopulos vs. City of Legaspi to underscore that when a right or fact has been judicially tried and determined, the judgment should be conclusive upon the parties and should bring an end to litigation.
Main Doctrine
The doctrine of res judicata bars the relitigation of issues that have been previously passed upon and decided by a court of competent jurisdiction, even if the subsequent case involves a different procedural posture, as long as the parties and the subject matter are the same. Supervening events, to be a valid ground for quashing a writ of execution of a final and executory judgment, must be of such a nature as to render the execution unjust and impossible, and not merely to re-open issues already decided.