Case Digest (G.R. No. L-9223)
Facts:
The case of Eduardo Brillantes vs. Leonardo Castro, G.R. No. L-9223, was decided on June 30, 1956, by the Supreme Court of the Philippines. The respondent, Leonardo Castro, operated under the business name "Almacas Police Protective Bureau," while the appellant was Eduardo Brillantes. On December 1, 1953, Brillantes filed a complaint against Castro with the Wage Administration Service for the alleged recovery of unpaid salary and overtime pay, designated as case No. C-1046. Subsequently, on February 15, 1954, both parties entered into an arbitration agreement, consenting to submit their case for investigation by the Wage Administration Service and to abide by the decision rendered by this body. After a hearing, a decision was issued by the Wage Administration Service on May 31, 1954, wherein Brillantes' claims for overtime and underpayment were dismissed, but Castro was ordered to pay Brillantes P50.88 for services rendered in November 1953, with payment due withi
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Case Digest (G.R. No. L-9223)
Facts:
- Initial Complaint and Arbitration Agreement
- On December 1, 1953, Eduardo Brillantes (plaintiff) filed a complaint against Leonardo Castro (defendant) before the Wage Administration Service (WAS) for unpaid salary and overtime pay (Case No. C-1046).
- On February 15, 1954, both parties entered into an arbitration agreement, agreeing to submit the case to the WAS for investigation and to abide by its decision, which they recognized as final and conclusive.
- WAS Decision
- On May 31, 1954, the WAS rendered a decision dismissing Brillantes' claim for overtime and underpayment but ordered Castro to pay P50.88 for unpaid salary for November 1953.
- No appeal was filed against this decision.
- Subsequent Complaint in Court
- On November 10, 1954, Brillantes filed a complaint in the Court of First Instance of Manila, seeking the same relief as in the WAS case.
- Castro filed a motion to dismiss, arguing that the WAS decision was final and conclusive.
- Trial Court's Decision
- The trial court granted the motion to dismiss, holding that the WAS decision was final and binding under Republic Act No. 602 (Minimum Wage Law) and the arbitration agreement.
Issues:
- Whether the decision of the Wage Administration Service (WAS) is final and conclusive, barring Brillantes from filing a subsequent case in court.
- Whether the doctrine of res judicata applies to decisions rendered by quasi-judicial bodies like the WAS.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)