Azuelo v. Zameco II Electric Cooperative, Inc.
NEW DOCTRINEFacts
The Antecedents: Petitioner Ricardo N. Azuelo (Azuelo) was employed by respondent ZAMECO II Electric Cooperative, Inc. (ZAMECO) as a maintenance worker. Azuelo filed a complaint for illegal dismissal and non-payment of benefits against ZAMECO. After several mediations, the Labor Arbiter (LA) ordered the parties to submit their respective position papers. Azuelo repeatedly failed to submit his position paper despite extensions granted by the LA, instead filing motions for the production of investigation reports. On November 6, 2006, the LA dismissed the case for lack of interest. Procedural History: Azuelo filed a second complaint for illegal dismissal with the same allegations. ZAMECO moved to dismiss the second complaint on the ground of res judicata, arguing that the first complaint was dismissed with prejudice. The LA dismissed the second complaint, holding that the dismissal of the first complaint was with prejudice. The National Labor Relations Commission (NLRC) affirmed the LA's decision, stating that the dismissal for failure to prosecute was with prejudice as it was unqualified. The Court of Appeals (CA) denied Azuelo's petition for certiorari, upholding the NLRC's ruling that the dismissal of the first complaint barred the refiling of the second complaint due to res judicata. The Petition: Azuelo filed a petition for review on certiorari with the Supreme Court, seeking to annul the CA's decision and resolution, essentially questioning whether the dismissal of his first complaint for illegal dismissal due to lack of interest bars the filing of another complaint for illegal dismissal based on the same allegations.
Issue(s)
Whether the dismissal of Azuelo's first complaint for illegal dismissal, on the ground of lack of interest to prosecute, bars the filing of another complaint for illegal dismissal against ZAMECO based on the same allegations. Whether the Court of Appeals committed grave abuse of discretion in affirming the dismissal of Azuelo's second complaint for illegal dismissal on the ground of res judicata.
Ruling
The petition is denied. The Decision dated February 26, 2010 and Resolution dated June 10, 2010 of the Court of Appeals in CA-G.R. SP No. 107762 are affirmed.
Ratio Decidendi
On whether the dismissal of the first complaint bars the filing of another complaint: The Court held that the dismissal of Azuelo's first complaint for illegal dismissal due to his unreasonable failure to submit his position paper, despite ample opportunity, was an adjudication on the merits and with prejudice. This is because the Labor Arbiter's Order dated November 6, 2006, which dismissed the complaint, was unqualified. The Court applied Section 3, Rule 17 of the Rules of Court, which provides that dismissal for failure to prosecute or to comply with rules or orders has the effect of an adjudication upon the merits, unless otherwise declared by the court. This principle is applied suppletorily to labor arbitration proceedings in the absence of specific provisions in the NLRC Rules. Therefore, the filing of the second complaint for illegal dismissal based on the same allegations was barred by res judicata. On whether the Court of Appeals committed grave abuse of discretion: The Court found that the CA did not commit any reversible error in upholding the dismissal of Azuelo's second complaint. The CA correctly determined that the NLRC did not abuse its discretion in ruling that the dismissal of the first complaint was an adjudication on the merits. The CA's affirmation of the NLRC's decision, which in turn affirmed the LA's dismissal of the second complaint on the ground of res judicata, was in accordance with law and jurisprudence. The Court reiterated that the phrase 'grave abuse of discretion' implies a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction, which was not present in the CA's disposition.
Main Doctrine
The dismissal of a complaint for illegal dismissal due to the complainant's unreasonable failure to submit a position paper, when unqualified by the Labor Arbiter, is considered an adjudication on the merits and with prejudice, barring the refiling of the same complaint based on the same allegations.