Pinag-Isang Lakas ng Mga Manggagawa v. Malunes
REITERATIONFacts
1. The Antecedents: Petitioners, former rank-and-file employees of Metro Transit Organization, Inc. (Metro), a wholly-owned subsidiary of the Light Rail Transit Authority (LRTA), were dismissed from service following the non-renewal of the management contract between Metro and LRTA. Metro operated the LRT Line 1. The dismissal occurred after the Secretary of Labor and Employment issued a Return to Work Order following a strike staged by the employees' union, Pinag-isang Lakas ng mga Manggagawa sa LRT (PIGLAS). Petitioners claim their dismissal was without just cause and due process, and that Metro and LRTA are essentially the same business entity concerning their employment. 2. Procedural History: Petitioners filed a complaint for illegal dismissal and unfair labor practice. The Labor Arbiter ruled in their favor, ordering Metro and LRTA to jointly and severally pay back wages and separation pay. Metro and LRTA's appeal to the National Labor Relations Commission (NLRC) was dismissed for non-perfection due to failure to post the required bond. Metro's subsequent petition for certiorari before the Court of Appeals (CA) was dismissed for failure to file a motion for reconsideration. This dismissal was affirmed by the Supreme Court in G.R. No. 175460. Meanwhile, LRTA also filed a separate petition with the CA, which annulled the labor arbiter's and NLRC's rulings holding LRTA jointly and severally liable, citing lack of jurisdiction. This was affirmed by the Supreme Court in G.R. No. 182928. The Commission on Audit (COA) later denied petitioners' petition for money claims, ruling that LRTA is not liable and that the labor tribunals lacked jurisdiction over LRTA in the illegal dismissal case. 3. The Petition: Petitioners filed this Petition for Certiorari under Rule 64, in relation to Rule 65 of the Rules of Court, assailing the Decision and Resolution of the COA. They argue that the COA committed grave abuse of discretion by reversing and nullifying a final and executory decision of the Supreme Court in G.R. No. 175460, which affirmed the labor arbiter's decision holding LRTA solidarily liable. Petitioners contend that the COA's jurisdiction is limited to the execution stage of money judgments and that it exceeded its authority by setting aside a final judgment. They also argue that the dismissal of Metro's petition in G.R. No. 175460 was not purely technical and that subsequent Supreme Court rulings in cases like Mendoza, Pili, and Alvarez have abandoned prior rulings that excluded LRTA from labor jurisdiction, thus making LRTA solidarily liable as an indirect employer.
Issue(s)
Whether the Commission on Audit (COA) committed grave abuse of discretion amounting to lack or excess of jurisdiction when it denied the money claims of Malunes et al. against LRTA. Whether the COA committed grave abuse of discretion amounting to lack or excess of jurisdiction when it exercised appellate review power on the May 19, 2006 Resolution of the NLRC Third Division and the final and executory Decision dated April 14, 2008, of the Supreme Court Third Division which held LRTA solidarity liable to pay the judgment award to petitioners.
Ruling
The petition is devoid of merit. The Commission on Audit (COA) did not commit grave abuse of discretion. The Decision No. 2020-556 dated December 17, 2020 and Resolution No. 2022-009 dated January 28, 2022, in COA C.P. Case No. 2018-559, are AFFIRMED.
Ratio Decidendi
On the issue of whether the COA committed grave abuse of discretion in denying the money claims against LRTA: The Court held that the COA did not commit grave abuse of discretion. The core of the controversy lies in the conflicting rulings regarding LRTA's liability. While G.R. No. 175460, which affirmed the labor arbiter's decision holding Metro and LRTA jointly and severally liable, became final and executory, LRTA was not a party to the proceedings that led to that decision at the Court of Appeals (CA) level. Crucially, LRTA had separately pursued its case, and the Supreme Court, in G.R. No. 182928, definitively ruled that labor tribunals lack jurisdiction over LRTA in illegal dismissal cases because it is a GOCC with an original charter. This ruling in G.R. No. 182928 established that any judgment against LRTA in such cases is void and without legal effect. Therefore, the COA correctly relied on the binding pronouncement in G.R. No. 182928, which exempted LRTA from liability for illegal dismissal claims, rather than the ruling in G.R. No. 175460, to which LRTA was not a party and which did not definitively settle LRTA's liability on the merits. On the issue of whether the COA exercised appellate review power beyond its authority: The Court found no merit in the petitioners' assertion that the COA reversed a final and executory Supreme Court decision. The COA's action was not an alteration of the Court's ruling in G.R. No. 175460 but rather an adherence to the more definitive ruling in G.R. No. 182928, which specifically addressed LRTA's jurisdictional immunity in illegal dismissal cases. The principle of res judicata does not apply here because there was no identity of parties between G.R. No. 175460 and G.R. No. 182928, as Metro litigated for its own interests and not for LRTA's. The Court emphasized that a void judgment, such as one rendered by a tribunal without jurisdiction, can never attain finality and may be ignored. Thus, the COA's denial of the money claims against LRTA was based on established jurisprudence and not an act of grave abuse of discretion.
Main Doctrine
The Commission on Audit (COA) did not commit grave abuse of discretion in denying a petition for money claims against the Light Rail Transit Authority (LRTA) based on a final and executory judgment against the Metro Transit Organization, Inc. (MTOI), where the Supreme Court had previously ruled in a separate case (G.R. No. 182928) that the labor tribunals lacked jurisdiction over LRTA in illegal dismissal cases, rendering any judgment against LRTA in such matters void. The principle of res judicata does not apply when there is no identity of parties in the cases, and a void judgment can never attain finality.