Garcia v. Philippine Airlines
REITERATIONFacts
The Antecedents: Petitioner Rodolfo D. Garcia was assigned by Stellar Industrial Services, Inc. (Stellar), a contractor, to work for Philippine Airlines (PAL) from August 2, 1976, until January 24, 1990, performing janitorial services and later as a kitchen busboy. Stellar issued a last warning to petitioner on April 28, 1987, for absences. PAL, through Cristina W. Trinidad, requested Stellar for petitioner's immediate replacement on March 21, 1990, citing poor performance and being caught selling cigarettes while on duty. Stellar demanded an explanation from petitioner, who provided one on April 2, 1990. Stellar subsequently terminated petitioner's employment. Procedural History: In 1992, petitioner filed an illegal dismissal case against Stellar, PAL, and Trinidad. Separately, in 1988, Stellar employees, including petitioner, filed complaints for regularization against PAL. Labor Arbiter Jose De Vera ruled in favor of the Stellar employees, finding an employer-employee relationship with PAL. The NLRC initially affirmed this but later reversed its decision on September 25, 1996, declaring the employees as Stellar's employees. This NLRC decision was affirmed by the Supreme Court. Meanwhile, in the illegal dismissal case, Labor Arbiter Emerson C. Tumanon ruled in favor of petitioner, declaring his dismissal illegal and ordering reinstatement with backwages. On appeal, the NLRC reversed the Labor Arbiter, finding petitioner guilty of gross and habitual neglect and that Stellar was a legitimate independent contractor. The Court of Appeals (CA) modified the NLRC ruling, holding Stellar solely responsible for the pecuniary awards, affirming that Stellar was an independent contractor and PAL was not the employer. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, arguing that the CA committed grave abuse of discretion in absolving PAL from liability, asserting that PAL was his employer due to performing necessary functions, PAL's exercise of control over his work, and PAL's adoption of disciplinary rules.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in absolving Philippine Airlines (PAL) from liability, considering that petitioner claims PAL is his employer; and whether the doctrine of res judicata bars the relitigation of the employer-employee relationship between petitioner and PAL. Whether the petition was timely filed and whether the arguments raised involve questions of law appropriate for certiorari review.
Ruling
The petition is DENIED for lack of merit. The Court affirmed the Court of Appeals' ruling that Philippine Airlines (PAL) is not the petitioner's employer and thus cannot be held solidarily liable for illegal dismissal. The issue of employer-employee relationship between petitioner and PAL has been settled by prior final and executory judgments under the doctrine of res judicata.
Ratio Decidendi
On the issue of whether PAL is the petitioner's employer and solidarily liable for illegal dismissal, and whether res judicata applies: The Court held that the issue of the employer-employee relationship between petitioner and PAL had already been resolved in previous cases, specifically Stellar Employees Association v. Philippine Airlines and Stellar Industrial Services, Inc., and other consolidated regularization cases. In those cases, the NLRC, whose findings were affirmed by the Supreme Court, definitively ruled that Stellar Industrial Services, Inc. (Stellar) was a legitimate independent contractor and the true employer of the complainants, not PAL. This prior adjudication, having attained finality, operates as res judicata on the same issue in the present petition. The Court emphasized that res judicata is founded on public policy and the hardship of being vexed twice for the same cause, ensuring an end to litigation. The doctrine of conclusiveness of judgment, a concept of res judicata, applies here because there is an identity of parties and subject matter (the employer-employee relationship), even though the causes of action (regularization vs. illegal dismissal) are different. Therefore, the parties are precluded from relitigating the existence of an employment relationship between petitioner and PAL. On the procedural issue of timely filing and the nature of arguments raised: The Court noted that the petition was filed beyond the requested extension period, but opted to resolve the petition on its merits in the greater interest of justice, considering the delay was not substantial. The Court reiterated that appeals by certiorari to the Supreme Court should raise only questions of law, as mandated by Rule 45, Section 1 of the Rules of Court. The petitioner's arguments primarily involved factual matters, such as the nature of his duties, PAL's control over his work, and PAL's disciplinary rules, which would require re-examination of evidence. While the Court may relax this rule in cases of conflicting findings between lower tribunals, it found no cogent reason to disturb the NLRC and CA findings, which were supported by substantial evidence. The Court found the petitioner's evidence lacking and his assertions unsubstantiated, particularly regarding PAL's control and disciplinary authority, contrasting with evidence showing Stellar's engagement, payment, discipline, and recognition of employment relationship through a Collective Bargaining Agreement (CBA).
Main Doctrine
The doctrine of res judicata, specifically the concept of conclusiveness of judgment, bars the relitigation of the issue of employer-employee relationship between parties when that issue has been previously determined in a final and executory judgment, even if the cause of action in the subsequent case is different.