Quadra v. Philippine Charity Sweepstakes Office
REITERATIONFacts
The Antecedents: Petitioner Geronimo Q. Quadra, Chief Legal Officer of the Philippine Charity Sweepstakes Office (PCSO), organized and participated in union activities, leading to his administrative charge for neglect of duty and misconduct before the Civil Service Commission. The Civil Service Commission found him guilty and recommended dismissal. PCSO dismissed him on July 15, 1965. Petitioner filed a motion for reconsideration and, along with the union, a complaint for unfair labor practice against PCSO before the Court of Industrial Relations (CIR). Procedural History: The CIR found PCSO guilty of unfair labor practice and ordered petitioner's reinstatement with backwages. PCSO complied but filed a petition for review with the Supreme Court. During the pendency of the SC case, petitioner filed a "Petition for Damages" with the CIR, praying for moral and exemplary damages, citing Rheem of the Philippines, Inc., et al. v. Ferrer, et al. PCSO moved to dismiss the petition for damages on grounds of lack of jurisdiction, bar by prior judgment, and failure to state a cause of action. Petitioner resigned on August 18, The petition for damages remained pending until the CIR was abolished and the National Labor Relations Commission (NLRC) was created. An Labor Arbiter awarded P1.6 million in moral and exemplary damages, which the NLRC affirmed. The Petition: The Court of Appeals reversed the NLRC decision, holding that the dismissal was not tainted with bad faith and that the damages claim constituted splitting of cause of action. Petitioner seeks review of the Court of Appeals' decision, arguing that the CA ruling on bad faith contradicts the final and executory CIR decision, and that the claim for damages did not constitute splitting of cause of action due to the prevailing law at the time of the initial filing.
Issue(s)
Whether the Court of Appeals erred in ruling that the dismissal of the petitioner was not tainted with bad faith, contrary to the final and executory decision of the CIR. Whether the filing of a petition for damages constituted splitting of cause of action.
Ruling
The petition is impressed with merit. The assailed decision and resolution of the Court of Appeals are REVERSED and SET ASIDE. The decision of the NLRC in NLRC NCR Case No. 4312-ULP is REINSTATED.
Ratio Decidendi
On the issue of bad faith and the finality of the CIR decision: The Court held that the ruling of the Court of Appeals that PCSO did not act in bad faith when it dismissed the petitioner is contrary to the already final and executory decision of the CIR dated November 19, 1966. The CIR had found PCSO guilty of bad faith and unfair labor practice in dismissing the petitioner due to his union activities. This decision was affirmed by the Supreme Court in G.R. No. L-27546 (later reported as PCSO, et al. v. Geronimo Q. Quadra, et al., 115 SCRA 34). The Court of Appeals has no jurisdiction to amend a final and executory decision. Once a decision becomes final and executory, it can no longer be amended or altered. The Court reiterated that a dismissed employee is entitled to moral damages when the dismissal is attended by bad faith or fraud or constitutes an act oppressive to labor, or is done in a manner contrary to good morals, good customs or public policy. Exemplary damages may be awarded if the dismissal is effected in a wanton, oppressive or malevolent manner. The facts showed that petitioner was deliberately dismissed due to his active involvement in union activities, which constituted unfair labor practice intended to interfere with employees' right to self-organization. On the issue of splitting of cause of action: The Court agreed with the petitioner that the filing of a petition for damages before the CIR did not constitute splitting of cause of action under the Revised Rules of Court. The Revised Rules of Court prohibits parties from instituting more than one suit for a single cause of action, which is the act of dividing a single cause of action into two or more parts and bringing suit for only one part, intending to reserve the rest for another action. The purpose is to avoid harassment and multiplicity of suits. However, the prevailing rule at the time the action for unfair labor practice and illegal dismissal was filed and tried before the CIR was that said court had no jurisdiction over claims for damages. Therefore, the petitioner could not have raised the issue of damages in the initial proceedings. It was only after the Supreme Court's ruling in Rheem of the Philippines, Inc., et al. v. Ferrer, et al. on January 27, 1967, which upheld the CIR's jurisdiction over claims for damages incidental to an employee's illegal dismissal, that the petitioner properly filed his claim for damages. This filing occurred before the ruling on their case became final and thus could not be considered splitting of cause of action.
Main Doctrine
A dismissed employee is entitled to moral damages when the dismissal is attended by bad faith or fraud or constitutes an act oppressive to labor, or is done in a manner contrary to good morals, good customs or public policy. Exemplary damages may be awarded if the dismissal is effected in a wanton, oppressive or malevolent manner. The filing of a petition for damages before the CIR did not constitute splitting of cause of action when the prevailing rule at the time of the initial action did not grant the CIR jurisdiction over claims for damages.