Case Digest (G.R. No. 121189)
Facts:
- Petitioners: Gaudencio A. Aldovino and Anacleto G. Pimentel, employees of Atlantic Gulf and Pacific Company of Manila, Inc. (AG & P).
- Employment Dates: Pimentel began on April 25, 1985; Aldovino joined in June 1989.
- Union Membership: Both became regular members of the United Rank and File Association (URFA), the recognized labor union for AG & P's rank-and-file workers.
- Layoff Directive: On July 25, 1991, AG & P announced temporary layoffs due to financial losses affecting many employees.
- Union Response: URFA filed a notice of strike, leading to a conciliatory conference and an agreement to submit the layoff issue to voluntary arbitration.
- Financial Assistance: A financial assistance agreement was established on September 7, 1991, for laid-off employees.
- Layoff Notices: Aldovino and Pimentel received layoff notices on September 17, 1991, along with financial assistance.
- Arbitration Outcome: In January 1992, a voluntary arbitrator upheld AG & P's right to lay off employees.
- Legal Complaints: In 1994, Aldovino and Pimentel filed complaints against AG & P for unfair labor practices and illegal dismissal, which were consolidated.
- Labor Arbiter's Ruling: The Labor Arbiter ruled the layoffs illegal, but AG & P appealed, citing res judicata based on the earlier arbitration ruling.
- NLRC Decision: The NLRC sided with AG & P, stating the issue had been resolved in the company's favor.
Issue:
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Ruling:
- The Supreme Court dismissed the petition by Aldovino and Pimentel.
- The Court affirmed the NLRC resolutions dated February 18, 1995, and March 30, 1995.
- It held that res judicata barred the petitioners from contesting the legality o...(Unlock)
Ratio:
- For res judicata to apply, the former judgment must be final, the court must have jurisdiction, the judgment must be on the merits, and there must be identity of parties, subject matter, and causes of action.
- Aldovino and Pimentel, as URFA members, were bound by the voluntary arbitrator's decision, which upheld the legality of the layoffs.
- The union'...continue reading
Case Digest (G.R. No. 121189)
Facts:
The case of Aldovino v. National Labor Relations Commission (G.R. No. 121189) involves petitioners Gaudencio A. Aldovino and Anacleto G. Pimentel, who were employees of Atlantic Gulf and Pacific Company of Manila, Inc. (AG & P). Pimentel commenced his employment on April 25, 1985, while Aldovino was hired in June 1989. Both employees became regular members of the United Rank and File Association (URFA), the recognized labor union for AG & P's rank-and-file workers. On July 25, 1991, AG & P issued a directive for temporary layoffs due to significant financial losses, impacting a considerable portion of its workforce. In response to the layoffs, URFA filed a notice of strike, which led to a conciliatory conference between AG & P and URFA, resulting in an agreement to submit the layoff issue to voluntary arbitration. On September 7, 1991, a financial assistance agreement was established, providing support to laid-off employees during the layoff period. Aldovino and Pimentel received notices of temporary layoff on September 17, 1991, along with financial assistance. In January 1992, a voluntary arbitrator upheld AG & P's right to lay off employees. Subsequently, in 1994, Aldovino and Pimentel filed complaints against AG & P for unfair labor practices and illegal dismissal, which were consolidated for resolution. The Labor Arbiter ruled in favor of the petitioners, declaring their layoffs illegal. However, AG & P appealed, invoking the principle of res judicata based on the earli...