Almirante: Conclusiveness of judgment

·3 min read

AFTER their motions for reconsideration were denied by the National Labor Relations Commission (NLRC), both petitioner Angono Medics Hospital Inc. (AMHI) and respondent Antonina Q. Agabin (Agabin) filed a petition for certiorari before the Court of Appeals (CA). AMHI’s petition was docketed as CA-G.R. S.P. 113939 while that of Agabin was docketed as CA-G.R. S.P. 114001.

AMHI raised the issue of the Arbiter’s abuse of discretion “in not granting the motion for examination and in not setting the case for formal hearing before deciding the case on its merits, and in affirming a clearly illegal act of said Arbiter.” On the other hand, Agabin raised the issues of whether or not the NLRC committed grave abuse of discretion when it modified the decision of the Arbiter by limiting the award of backwages only from Dec. 19, 2007 until Jan. 16, 2008 instead of from September 19, 2007 until the finality of the decision.

The CA dismissed AMHI’s petition (SP 113939) in its July 19, 2010 decision. It upheld the illegal dismissal of Agabin. In Agabin’s SP 114001, the CA set aside the NLRC decision on the aspect of modifying the reckoning point of the award of separation pay and backwages.

Does the ruling in SP 113939 serves as res judicata upon SP 114001?

Ruling: Yes, with qualification.

The elements of res judicata are: (1) the judgment sought to bar the new action must be final; (2) the decision must have been rendered by a court having jurisdiction over the subject matter and the parties; (3) the disposition of the case must be a judgment on the merits; and (4) there must be as between the first and second action, identity of parties, subject matter, and causes of action. xxx Should identity of parties, subject matter, and causes of action be shown in the two cases, then res judicata in its aspect as a ‘bar by prior judgment’ would apply. If as between the two cases, only identity of parties can be shown, but not identical causes of action, then res judicata as “conclusiveness of judgment” applies (Monterona v. Coca-Cola Bottlers Philippines Inc., G.R. 209116, Jan. 14, 2019) .

The instant case should be resolved on the basis of the rule on “conclusiveness of judgment” since although there is identity of parties in both SP Nos. 113939 and 114001, the causes of action are not identical, as earlier discussed. Moreover, strictly speaking, there is only conclusiveness of judgment insofar as the finding of illegal dismissal is concerned and not as to the computation of the monetary awards.

In view of these considerations, the Court finds that there is no conflict between the two CA rulings. In SP 113939, the appellate court dealt with the illegal dismissal aspect of the case as well as the Arbiter’s denial of AMHI’s motion to further examine Agabin’s documents and to set the case for formal hearing.

On the other hand, in SP 114001, the CA delved on the correct basis and computation of Agabin’s backwages and separation pay. Relevantly, the appellate court in SP 113939 did not discuss at all the computation of the monetary awards; it merely quoted the rulings of both the Arbiter and the NLRC.

To reiterate, in SP 113939, while the appellate court affirmed both the rulings of the Arbiter and the NLRC as regards the issue of Agabin’s illegal dismissal, it did not delve into the computation of separation pay and backwages. In this regard, it cannot be said that there was a bar by conclusiveness of judgment by virtue of the finality of SP 113939 which would in turn bar Agabin from further contesting the computation of her monetary awards. As it stands, the said computation can still be questioned since the CA in SP 113939 did not expressly make a definitive finding that the NLRC’s ruling in limiting the award prevailed over the Arbiter’s Decision to grant full backwages and separation pay to Agabin. (Angono Medics Hospital Inc. vs. Antonina Q. Agabin, G.R. 202542, Dec. 9, 2020).

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