Bandillion v. La Filipina Uygongco Corp.
REITERATIONFacts
The Antecedents: Petitioners, employees of respondent La Filipina Uygongco Corporation (LFUC), filed a complaint for violation of labor standard laws. An initial inspection found no violation, which was upheld by the DOLE Regional Director. However, the Acting DOLE Secretary overturned this, finding LFUC liable for underpayment of wages, holiday pay, rest day pay, and overtime pay, and remanded the case for computation. Procedural History: LFUC's motion for reconsideration was denied, and its subsequent petition for certiorari with the Court of Appeals was also denied. This Court dismissed LFUC's petition for certiorari and its motion for reconsideration with finality. Subsequently, the DOLE Regional Director issued an Order directing LFUC to pay Php3,345,657.94 to its employees. A Writ of Execution was issued, but LFUC filed a Petition for certiorari and injunction with the Court of Appeals, arguing procedural defects and denial of due process. LFUC then filed a Motion for Reconsideration (treated as an appeal) with the DOLE Regional Director, again raising due process and evidentiary issues. This motion was denied, and the denial was affirmed by the DOLE Secretary. The Court of Appeals, however, granted LFUC's petition for certiorari, remanding the case to the DOLE Regional Director for reception of evidence and re-computation, finding that due process was not observed. The Petition: The employees filed a petition for review on certiorari with the Supreme Court, assailing the Court of Appeals' decision and resolution, arguing that LFUC's motion for reconsideration rendered its petition for certiorari moot and academic, constituting forum shopping. They also contended that LFUC was not denied due process.
Issue(s)
Whether LFUC's petition for certiorari before the Court of Appeals was rendered moot and academic by its subsequent filing of a motion for reconsideration with the DOLE-VI Regional Director, and whether LFUC committed forum shopping. Whether LFUC was denied due process. Whether the Court of Appeals erred in remanding the case for reception of evidence and re-computation of monetary awards. On the procedural issues raised by LFUC and the choice of remedy.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision and resolution, and ordered the Department of Labor and Employment and DOLE Region VI to proceed with the enforcement of the Writ(s) of Execution. Dispositive Portion: The petition is GRANTED. The Court of Appeals' Decision dated September 13, 2011 and Resolution dated May 24, 2012 in CA-GR. SP No. 03690 are REVERSED and SET ASIDE. The Department of Labor and Employment and DOLE Region VI are ORDERED TO PROCEED WITH DISPATCH IN THE ENFORCEMENT of the Writ(s) of Execution subject of this case.
Ratio Decidendi
On the issue of mootness and forum shopping: The Court held that LFUC's filing of a motion for reconsideration with the DOLE-VI Regional Director rendered moot and academic its petition for certiorari pending with the Court of Appeals. This act constituted forum shopping, as LFUC availed of two simultaneous remedies before different tribunals, raising the same issues and seeking substantially the same relief, thereby creating the possibility of conflicting decisions. The Court emphasized that forum shopping is an act of malpractice that degrades the administration of justice and adds to congested court dockets. The elements of litis pendentia were found to be present, as there was an identity of parties, causes of action, and reliefs sought, such that a judgment in one case would amount to res judicata in the other. The Court found that LFUC's petition for certiorari was an empty, duplicate exercise that should have been dismissed or withdrawn. On the issue of due process and reception of evidence: The Court found LFUC's allegations of denial of due process to be without merit. It noted that LFUC had several opportunities to submit evidence during the various stages of the proceedings before the DOLE, but failed to do so. Furthermore, a Subpoena Duces Tecum was served on LFUC to produce employment records, which it failed to comply with, despite a warning that computations would be based on available records. The Court also affirmed the DOLE Secretary's ruling that even piece-rate workers are entitled to holiday pay, rest day pay, and overtime pay, as they are considered supervised workers. The Court also found that waivers and quitclaims were not given credence as they were executed in violation of administrative requirements. On the issue of the Court of Appeals' ruling: The Court found that the Court of Appeals' ruling was not in agreement with the records and that its factual findings contradicted those of the DOLE and DOLE Region VI. The Court gave greater weight to the findings of the labor tribunals, which were supported by substantial evidence, and presumed that labor officials performed their duties regularly. The Court reiterated that the factual findings of labor administrative officials, if supported by substantial evidence, are entitled to great respect and even finality. On the procedural issues raised by LFUC and the choice of remedy: The Court found LFUC's procedural challenges to the petition to be without merit. It held that the Special Power of Attorney (SPA) signed by most petitioners, authorizing their union president to file the petition and sign the verification and certification against forum shopping, substantially complied with the rules. The Court also noted that the formal substitution of deceased workers was not necessary when their heirs voluntarily appeared and participated in the proceedings by signing the SPA. Lastly, the Court found that the copies of the Court of Appeals' resolutions attached to the petition were certified true copies, contrary to LFUC's allegations. The Court reiterated that a petition for certiorari is available only when there is no appeal or any plain, speedy, and adequate remedy in the ordinary course of law. Since LFUC had an adequate remedy in filing a motion for reconsideration and appeal with the DOLE, its resort to certiorari was improper. The Court chose to uphold the ruling of the DOLE Region VI, as it was issued by the proper and primary agency, and was the adequate remedy in the ordinary course of law, unlike certiorari which is an extraordinary remedy.
Main Doctrine
The filing of a motion for reconsideration before a labor tribunal renders moot and academic a petition for certiorari filed with the Court of Appeals assailing an earlier order from the same tribunal, and such act constitutes forum shopping, warranting the dismissal of the petition for certiorari.