Case Digest (G.R. No. 192573)
Facts:
The case involves Ricardo N. Azuelo (Petitioner) and ZAMECO II Electric Cooperative, Inc. (Respondent). Azuelo was employed as a maintenance worker by ZAMECO. In March 2006, he filed a complaint for illegal dismissal and non-payment of benefits against ZAMECO with the Regional Arbitration Branch (RAB) of the National Labor Relations Commission (NLRC) in San Fernando City, Pampanga. This complaint was assigned to Labor Arbiter Mariano L. Bactin and was docketed as NLRC Case No. RAB 111-03-9912-06. After several mediations, Azuelo was ordered to submit his position paper by July 14, 2006. Instead, he requested an extension until August 4, 2006, which was granted. However, he again failed to submit his position paper by the new deadline and requested another extension until August 22, 2006. On that date, instead of submitting the required document, Azuelo filed a motion for ZAMECO to provide him with a complete copy of the investigation report regarding his dismissal. ZAMECO opp...
Case Digest (G.R. No. 192573)
Facts:
Employment and Initial Complaint
- Petitioner Ricardo N. Azuelo (Azuelo) was employed by respondent ZAMECO II Electric Cooperative, Inc. (ZAMECO) as a maintenance worker.
- In March 2006, Azuelo filed a complaint for illegal dismissal and non-payment of benefits against ZAMECO with the Regional Arbitration Branch (RAB) of the NLRC in San Fernando City, Pampanga, docketed as NLRC Case No. RAB 111-03-9912-06.
- Labor Arbiter (LA) Mariano L. Bactin (LA Bactin) was assigned to the case.
Failure to Submit Position Paper
- On July 14, 2006, Azuelo requested an extension to submit his position paper, which was granted until August 4, 2006.
- On August 4, 2006, Azuelo again failed to submit his position paper and was given another extension until August 22, 2006.
- On August 22, 2006, instead of submitting his position paper, Azuelo moved for an order directing ZAMECO to furnish him with a complete copy of the investigation report regarding his dismissal. ZAMECO opposed this motion, stating it had already provided the report.
Dismissal of First Complaint
- On November 6, 2006, LA Bactin dismissed Azuelo's complaint for lack of interest, as Azuelo failed to submit his position paper despite ample opportunity.
- Azuelo received the dismissal order on November 17, 2006.
Second Complaint and Motion to Dismiss
- On November 21, 2006, Azuelo filed a second complaint for illegal dismissal with the same allegations, docketed as NLRC Case No. RAB-III-11-10779-06, assigned to LA Reynaldo V. Abdon (LA Abdon).
- On December 20, 2006, ZAMECO filed a Motion to Dismiss, arguing res judicata since the first complaint had already been dismissed.
- Azuelo opposed the motion, claiming the dismissal of the first complaint was without prejudice and that he was unable to submit his position paper due to ZAMECO's refusal to provide necessary documents.
Dismissal of Second Complaint
- On March 12, 2007, LA Abdon dismissed Azuelo's second complaint on the ground of res judicata, stating that the dismissal of the first complaint was with prejudice.
- The NLRC affirmed this decision on September 22, 2008, and denied Azuelo's motion for reconsideration on December 15, 2008.
Appeal to the Court of Appeals
- Azuelo filed a petition for certiorari with the CA, arguing that the NLRC gravely abused its discretion in ruling that the dismissal of his first complaint was with prejudice.
- On February 26, 2010, the CA denied the petition, holding that the NLRC did not commit any abuse of discretion.
- The CA also denied Azuelo's motion for reconsideration on June 10, 2010.
Issue:
The primary issue is whether the dismissal of Azuelo's first complaint for illegal dismissal, due to his failure to submit his position paper, bars the filing of a second complaint for illegal dismissal based on the same allegations.
Ruling:
The Supreme Court denied the petition, affirming the CA's decision. The Court held that:
- The dismissal of Azuelo's first complaint was with prejudice, as the order did not specify otherwise.
- The failure to submit a position paper despite ample opportunity constitutes a failure to prosecute, warranting dismissal with prejudice.
- The doctrine of res judicata applies, barring the filing of a second complaint based on the same allegations.
- Azuelo should have appealed the dismissal of his first complaint instead of filing a new complaint.
Ratio:
- Dismissal with Prejudice: Under Section 3, Rule 17 of the Rules of Court, a dismissal for failure to prosecute is deemed an adjudication on the merits and with prejudice unless the order states otherwise. Since LA Bactin's order was unqualified, the dismissal was with prejudice.
- Res Judicata: The doctrine of res judicata bars the re-filing of a complaint based on the same cause of action, parties, and subject matter after a final judgment has been rendered.
- Failure to Prosecute: Azuelo's failure to submit his position paper despite multiple extensions showed a lack of interest in prosecuting his case, justifying the dismissal with prejudice.
- Wrong Remedy: Azuelo should have appealed the dismissal of his first complaint within 10 days instead of filing a new complaint. His failure to do so rendered the dismissal final and executory.
Conclusion:
The Supreme Court upheld the CA's decision, ruling that the dismissal of Azuelo's first complaint was with prejudice and barred the filing of a second complaint under the doctrine of res judicata. Azuelo's failure to prosecute his case and his choice of the wrong remedy led to the dismissal of his claims.