Case Summary (G.R. No. 207684)
Background of the Dispute
The respondents were all members of the Philtranco Workers Union Association of Genuine Labor Organization (PWU-AGLO) and were included in Philtranco’s retrenchment program. This program was cited by Philtranco as a necessary measure due to business losses. The PWU-AGLO subsequently filed a Notice of Strike with the Department of Labor and Employment (DOLE), alleging unfair labor practices. Efforts to settle the disputes were unsuccessful, leading to formal complaints and hearings.
Findings of the DOLE and Initial Cases
On June 13, 2007, the Acting DOLE Secretary ruled that 17 union officers had been illegally terminated. Key directives included their reinstatement, the payment of back wages, and the preservation of existing collective bargaining agreement (CBA) terms. The respondents contended they were not reinstated and filed a labor complaint for illegal dismissal on October 16, 2007, which was initially dismissed due to procedural technicalities regarding the verification page of their earlier filed complaints.
Subsequent Developments in the NLRC
In a subsequent resolution, the Labor Arbiter determined that some employees had been illegally dismissed and ordered their reinstatement and payment of back wages. The National Labor Relations Commission (NLRC), upon Philtranco’s appeal, reversed this decision, giving weight to new financial statements submitted by the petitioner. This action positioned the second complaint as distinct from the first, leading to legal complexities.
Appeals to the Court of Appeals
The CA eventually reinstated the Labor Arbiter's earlier findings, concluding that the retrenchment program had been improperly justified as Philtranco failed to present substantive evidence of financial distress. The CA also maintained that the retroactive application of the law of the case principle was inappropriate in this instance.
Supreme Court’s Ruling
The core issue before the Supreme Court was whether the CA had correctly applied the law of the case doctrine in this context. The Court clarified that the doctrine does not extend to a new complaint and that the retrenchment's validity from the first NLRC case was binding due to the res judicata concept. This in
...continue readingCase Syllabus (G.R. No. 207684)
Background of the Case
- The case involves a Petition for Review on Certiorari under Rule 45, contesting the Decision of the Court of Appeals (CA) dated November 9, 2012, and its subsequent Resolution denying reconsideration.
- The CA reinstated the Labor Arbiter's finding that Philtranco Service Enterprises, Inc. (Philtranco) illegally dismissed the respondents, who were drivers, conductors, and maintenance personnel.
Antecedents
- Respondents were members of the Philtranco Workers Union Association of Genuine Labor Organization (PWU-AGLO) and were included in a retrenchment program during 2006-2007 due to claimed business losses.
- PWU-AGLO filed a Notice of Strike with the Department of Labor and Employment (DOLE), alleging unfair labor practices leading to the case being docketed as NCMB-NCR Case No. NS-02-028-07.
- After failed negotiations, the case was referred to the DOLE Secretary, who issued a decision on June 13, 2007, mandating reinstatement of illegally terminated employees and ordering Philtranco to maintain the status quo of existing terms and conditions.
Initial Labor Complaint
- Following the decision from DOLE, respondents filed a labor complaint on October 16, 2007, for illegal dismissal, which was docketed as NLRC NCR Case No. 00-10-11607-07.
- Labor Arbiter Antonio Macam found union president Jose Jessie Olivar was illegally dismissed but dismissed t