Libongcogon v. Phimco Industries
REITERATIONFacts
The Antecedents: PHIMCO Industries, Inc. (PHIMCO) and Phimco Labor Association (PILA) experienced a bargaining deadlock, leading PILA to stage a strike on April 21, 1995. Despite a temporary restraining order, the strike continued with strikers blocking ingress and egress. PHIMCO subsequently dismissed strikers for alleged illegal acts. PILA filed a complaint for illegal dismissal and unfair labor practice. PHIMCO filed a petition to declare the strike illegal. The Secretary of Labor assumed jurisdiction and issued a return-to-work order. PHIMCO later laid off 21 employees and implemented a retirement program for 53 others. Seven employees, including Florencio Libongcogon, Felipe Villareal, and Alfonso Claudio, dismissed on June 26, 1995, were not included in the initial illegal dismissal case. PILA filed another complaint for illegal dismissal of these 7 employees, forced retirement of 53, and layoff of 21. Procedural History: The Labor Arbiter dismissed PILA's second complaint. The NLRC affirmed this dismissal. The Court of Appeals (CA) partly granted PILA's petition, finding the 7 employees illegally dismissed, entitling them to reinstatement and backwages. This CA decision became final and executory. Subsequent computations of backwages were made. Some employees settled their claims via quitclaims. PHIMCO argued that the positions of Libongcogon, Villareal, and Claudio were abolished, making reinstatement impossible and entitling them only to separation pay. Labor Arbiter Aliman D. Mangandog upheld PHIMCO's position, ordering separation pay. The NLRC reversed LA Mangandog, remanding the case for strict enforcement of the CA decision. The NLRC later modified its resolution, dismissing the case for some employees who executed quitclaims and ordering specific backwages for Libongcogon, Villareal, and Claudio. PHIMCO appealed to the CA, arguing grave abuse of discretion by the NLRC. The CA initially denied PHIMCO's petition, upholding the NLRC. However, upon reconsideration, the CA granted PHIMCO's motion, amending its decision. The CA invoked this Court's rulings in the 'illegal strike case' (G.R. No. 170830) and the 'illegal dismissal case' (G.R. No. 192875) as supervening events that rendered the prior executory decision unenforceable, reversing the NLRC resolutions concerning the reinstatement and backwages of Libongcogon, Villareal, and Claudio. The Petition: Libongcogon, Villareal, and Claudio (petitioners) appealed to the Supreme Court, arguing that the CA committed grave abuse of discretion by setting aside its previous decision and granting PHIMCO's motion for reconsideration based on subsequent Supreme Court rulings, which they contend were not properly raised and did not constitute valid supervening causes that could alter a final and executory judgment.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in amending its decision and relying on subsequent Supreme Court rulings as supervening events to set aside a final and executory decision. Whether the Supreme Court's rulings in G.R. No. 170830 (illegal strike case) and G.R. No. 192875 (illegal dismissal case) constitute supervening causes that render the enforcement of the February 27, 2001 CA decision (CA-G.R. SP No. 57988) unjust and inequitable. Whether the petitioners, identified as participants in illegal acts during the strike, can still claim illegal dismissal and reinstatement despite the finality of the decision in their favor.
Ruling
The petition is dismissed for lack of merit. The amended decision dated August 30, 2012, of the Court of Appeals is affirmed.
Ratio Decidendi
On whether the CA committed grave abuse of discretion and the applicability of supervening events: The Court disagreed with the petitioners' contention that the CA contravened the doctrine of immutability of final judgments. The Court reiterated that this doctrine admits exceptions, one of which is the existence of a supervening cause or event that renders the enforcement of a final and executory decision unjust and inequitable. In this case, the Court found that such a supervening event transpired. The evidence in the 'illegal strike case' (G.R. No. 170830) clearly identified the petitioners as among the union members who committed illegal acts during the strike, specifically blocking ingress and egress, which are prohibited acts under Article 264(e) of the Labor Code. This Court's ruling in the illegal strike case, which attained finality, became the basis for the Court's Second Division in rejecting the prayer for reinstatement of dismissed union members in the 'illegal dismissal case' (G.R. No. 192875), thereby recognizing the validity of their dismissal. Therefore, the CA correctly opined that these subsequent rulings constituted an intervening cause that made the prior executory decision of the CA Special 12th Division unenforceable. On the validity of dismissal despite a prior favorable judgment: The Court emphasized that a strike enjoys recognition and respect only when it complies with legal conditions, including the avoidance of illegal acts. The petitioners were positively found to have committed illegal acts during the strike, which is a prohibited act under the law. The prior decision of the CA Special 12th Division declaring their dismissal illegal was based on the finding that there was no showing at the time that they committed illegal acts. However, subsequent Supreme Court decisions in the illegal strike and illegal dismissal cases proved otherwise, positively identifying the petitioners as participants in illegal acts. To allow their reinstatement and award them backwages would be unjust to the company and to other dismissed union members whose dismissals were upheld due to their participation in illegal acts during the strike. The Court found it unfair for the petitioners to be spared from liability for their illegal acts by invoking the doctrine of immutability of final judgments when they were respondents in the illegal strike case and were positively identified as having committed illegal acts. On the application of res judicata and the finality of judgments: The Court clarified that while a decision becomes final and executory, its execution may be modified or altered if it becomes impossible or unjust due to supervening facts. The Court found that the pronouncements in G.R. No. 170830 and G.R. No. 192875, which established the petitioners' participation in illegal acts during the strike and validated their dismissal, constituted supervening events. These rulings effectively resolved the issue of the petitioners' illegal dismissal, making the prior CA decision enforcing their reinstatement unenforceable. The Court noted that PHIMCO had consistently raised the issue of supervening events in its subsequent pleadings before the CA. The Court concluded that the CA correctly yielded to the pronouncements of the Supreme Court in the two cases on the ground of res judicata, as the cases involved an identity of parties and issues, and the subsequent rulings rendered the execution of the NLRC resolution unjust and inequitable.
Main Doctrine
The doctrine of immutability of final judgments admits of exceptions, including the existence of a supervening cause or event that renders the enforcement of a final and executory decision unjust and inequitable. Subsequent Supreme Court rulings that positively identify employees as participants in illegal acts during a strike, thereby validating their dismissal, can constitute such a supervening cause, overriding a prior executory decision declaring their dismissal illegal.