Dela Rosa Liner v. Borela
REITERATIONFacts
The Antecedents: Respondents Calixto Borela and Estelo Amarille, a bus driver and conductor respectively, filed separate complaints, later consolidated, against petitioners Dela Rosa Liner, Inc., Rosauro Dela Rosa, Sr., and Nora Dela Rosa. The complaints alleged underpayment/non-payment of salaries, holiday pay, overtime pay, service incentive leave pay, 13th-month pay, sick and vacation leave, night shift differential, illegal deductions, and violations of Wage Orders. Procedural History: The Labor Arbiter initially dismissed the respondents' complaint for forum shopping, citing a prior compromise agreement between the parties. However, the National Labor Relations Commission (NLRC) reversed this dismissal, finding no identity of causes of action between the two cases. The petitioners sought review from the Court of Appeals (CA), arguing grave abuse of discretion by the NLRC. The CA denied the petition, affirming the NLRC's ruling that forum shopping and res judicata did not bar the respondents' claims. The CA noted that the first case involved illegal dismissal and unfair labor practice, while the second concerned labor standards benefits. The Petition: Petitioners seek a review on certiorari of the CA's decision, contending that the appellate court erred in upholding the NLRC's finding that the respondents did not commit forum shopping or that the case was not barred by res judicata. They argue that the prior compromise agreement, which settled all claims related to the respondents' employment, should preclude the current action. The petitioners assert that the respondents should not be allowed to pursue these claims after receiving a considerable settlement amount.
Issue(s)
Whether the petition for review on certiorari was filed on time. Whether the respondents committed forum shopping or if their second complaint is barred by res judicata. Whether the compromise agreement in the first case covered the claims in the second complaint.
Ruling
The petition is dismissed for lack of merit. The assailed decision and resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the timeliness of the petition: The Court found the petition for review on certiorari to be timely filed. Although the petitioners' counsel received the CA resolution denying their motion for reconsideration on May 28, 2013, giving them until June 12, 2013, to file the petition, the petition was notarized on June 13, 2013. However, June 12, 2013, was Independence Day, a legal holiday. Pursuant to Section 1, Rule 22 of the Rules of Court, when the last day for filing falls on a holiday, the filing on the next working day is considered timely. Therefore, filing on June 13, 2013, complied with the rules. On forum shopping and res judicata: The Court affirmed the CA's ruling that the second complaint was not barred by forum shopping or res judicata. The elements of forum shopping require identity of parties, rights asserted, relief prayed for, and causes of action, such that any judgment would amount to res judicata. The Court found no identity of causes of action between the first complaint (illegal dismissal, unfair labor practice) and the second complaint (labor standards benefits, violation of wage orders). The evidence required for each case is different, meaning a judgment in the first would not be res judicata in the second. Therefore, the filing of the second complaint did not constitute forum shopping. On the scope of the compromise agreement: The Court held that the compromise agreement, which settled the illegal dismissal and unfair labor practice case, did not cover the labor standards claims in the second complaint. While the agreement stated it applied to all claims and causes of action, it specified "on the same grounds," referring to the issues in the first complaint. Furthermore, the Court emphasized that certain labor claims, such as those for 13th-month pay, overtime pay, and statutory wages under wage orders, are granted for workers' protection and welfare and cannot be generally waived without appropriate consideration. The Court noted that the compromise agreement was executed on September 8, 2011, while the labor standards complaint was filed on September 23, 2011, indicating the latter was not contemplated in the settlement.
Main Doctrine
The filing of a second complaint for labor standards benefits, which involves different causes of action and requires different evidence than a prior complaint for illegal dismissal and unfair labor practice settled by a compromise agreement, does not constitute forum shopping or is barred by res judicata. General waivers in compromise agreements cannot cover non-waivable labor claims.