Case Digest (G.R. No. 76142-43)
Facts:
VDA Fish Broker and/or Venerando Alonzo v. National Labor Relations Commission, Ruperto Bula and Virgilio Salac, G.R. Nos. 76142-43, December 27, 1993, Supreme Court First Division, Bellosillo, J., writing for the Court.Petitioner VDA Fish Broker (represented by Venerando D. Alonzo) is a licensed fish broker engaged in selling fish; respondents Ruperto Bula and Virgilio Salac are batilyos who arranged fish in the banera and performed related tasks. On May 14, 1982, a complaint for nonpayment of various statutory benefits was filed against VDA by the Samahan ng Nagkakaisang Batilyo–NFL, represented by Bula, with Salac also signing; this was docketed as Case No. NLRC‑NCR‑5‑3832‑82.
On May 26, 1983, Labor Arbiter Porfirio E. Villanueva dismissed Case No. NLRC‑NCR‑5‑3832‑82, finding no employer-employee relationship: the batilyos allegedly worked for themselves, were paid by results, had no regular hours, and could transfer to other brokers. No appeal was taken from that dismissal. Later, claiming termination on or about January 1, 1984, Salac and Bula filed separate illegal dismissal complaints (Case Nos. NLRC‑NCR‑1‑153‑84 and NLRC‑NCR‑1‑169‑84).
On August 28, 1984, Labor Arbiter Adelaido F. Martinez dismissed those illegal dismissal complaints for lack of employer-employee relationship. The NLRC, however, on August 8, 1986, reversed the Labor Arbiter, directed reinstatement of Salac and Bula with back wages, and thus concluded they were employees of VDA. Petition for certiorari, prohibition and mandamus challenging the NLRC decision was filed on October 17, 1986; a temporary restraining order was issued on October 27, 1986. The Office of the Solicitor General supported petitioner’s res judicata argument; the NLRC filed a comment defending its decision.
The Supreme Court considered whether the earlier administrative adjudication on employer-employee relationship in Case No. NLRC‑NCR‑5‑3832‑82 was conclusive in the later illegal dismissal procee...(Pro-only)
Issues:
- Did the NLRC err in refusing to treat the prior administrative determination that no employer‑employee relationship existed (Case No. NLRC‑NCR‑5‑3832‑82) as conclusive by way of res judicata in the later illegal dismissal cases (NLRC‑NCR‑1‑153‑84 and NLRC‑NCR‑1‑169‑84)?
- Could the certification‑election order in Case No. NCR‑LRD‑M‑4‑143‑82 be treated as dispositive of the complainants’ employee status and thus ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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