Case Digest (G.R. No. L-25649)
Facts:
The case involves Eddie del Castillo and fifteen co-plaintiffs, all members of the Associated Labor Union, who filed an appeal against the Central Azucarera de la Carlota and the National Sugar Workers' Union (PAFLU) after the Court of First Instance of Cebu dismissed their complaint for moral and exemplary damages amounting to P160,000, along with attorney's fees of P10,000. The events leading to this case began in 1962 when the plaintiffs, who were laborers at the Central Azucarera, were members of the National Sugar Workers' Union. In April or May of that year, the Associated Labor Union submitted proposals for a collective bargaining agreement to the Central, which were rejected. Following this, the Associated Labor Union filed petitions for a certification election with the Court of Industrial Relations (CIR) in Iloilo City. During this process, Simplicio Lopez, Jr., a signatory to the petitions, was suspended by the Central. The plaintiffs actively campaigne...
Case Digest (G.R. No. L-25649)
Facts:
Parties Involved:
- Plaintiffs-Appellants: Eddie del Castillo and fifteen co-plaintiffs, along with the Associated Labor Union.
- Defendants-Appellees: Central Azucarera de la Carlota and the National Sugar Workers' Union (PAFLU).
Nature of the Case:
- The plaintiffs filed a complaint for moral and exemplary damages amounting to P160,000 and attorney's fees of P10,000, alleging unfair labor practices by the defendants.
Background of the Dispute:
- The sixteen individual plaintiffs were laborers at Central Azucarera de la Carlota and were members of the National Sugar Workers' Union until July 24, 1962.
- In April or May 1962, the Associated Labor Union submitted collective bargaining proposals to the Central, which were rejected.
- The Associated Labor Union then filed petitions for a certification election with the Court of Industrial Relations (CIR), docketed as Cases Nos. 57-MC-Iloilo and 58-MC-Iloilo.
- Simplicio Lopez, Jr., a signatory to the petitions, was suspended by the Central.
- The plaintiffs resigned from the National Sugar Workers' Union and actively campaigned for the Associated Labor Union.
Unfair Labor Practice Allegations:
- During the pendency of the certification election petitions, the Central, allegedly at the instance of the National Sugar Workers' Union, dismissed the plaintiffs for resigning from the Union and joining the Associated Labor Union.
- The plaintiffs filed an unfair labor practice case (Case No. 3385-ULP-Iloilo) with the CIR, which found the defendants guilty and ordered the reinstatement of the plaintiffs with back wages.
Subsequent Action for Damages:
- The plaintiffs filed a separate action in the Court of First Instance of Cebu for moral and exemplary damages, claiming that the unfair labor practices caused them and their families suffering.
- The defendants moved to dismiss the complaint on grounds of lack of jurisdiction, lack of cause of action, and res judicata.
Lower Court Decision:
- The Court of First Instance dismissed the complaint on the ground of res judicata, holding that the claim for damages was already addressed in the CIR decision.
Issue:
- Whether the Court of First Instance of Cebu had jurisdiction to entertain a complaint for damages arising from alleged unfair labor practices.
- Whether the claim for damages was barred by the prior judgment of the CIR in the unfair labor practice case.
- Whether the plaintiffs' action for damages based on quasi-delict (tortious acts) could proceed independently of the CIR decision.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)