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    Delfin vs. Inciong

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    Rona Tumagan
    The case involves a union filing a complaint against their employer for not following their collective bargaining agreement. The case was previously dismissed and the dismissal was upheld. The union then filed the same complaint again but naming individual union members instead of the union. The court ruled the new case was barred by res judicata since it involved the same parties, subject matter, and cause of action as the previous case.

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    Delfin vs. Inciong

    Uploaded by

    Rona Tumagan
    16 views2 pages
    The case involves a union filing a complaint against their employer for not following their collective bargaining agreement. The case was previously dismissed and the dismissal was upheld. The union then filed the same complaint again but naming individual union members instead of the union. The court ruled the new case was barred by res judicata since it involved the same parties, subject matter, and cause of action as the previous case.

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    The case involves a union filing a complaint against their employer for not following their collective bargaining agreement. The case was previously dismissed and the dismissal was upheld. The union then filed the same complaint again but naming individual union members instead of the union. The court ruled the new case was barred by res judicata since it involved the same parties, subject matter, and cause of action as the previous case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    16 views2 pages

    Delfin vs. Inciong

    Uploaded by

    Rona Tumagan
    The case involves a union filing a complaint against their employer for not following their collective bargaining agreement. The case was previously dismissed and the dismissal was upheld. The union then filed the same complaint again but naming individual union members instead of the union. The court ruled the new case was barred by res judicata since it involved the same parties, subject matter, and cause of action as the previous case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    FACTS:

    The Atlantic Container Employees Organization and affiliated with the Federation of Democratic Labor
    Unions (FEDLU), composed of 136 employees, filed a complaint against their employer, respondent
    Atlantic Container Corporation, for not executing the contents of their collective bargaining agreement.
    The said union filed a case of unfair labor practice (ULP) against the employer. However, upon trial, it was
    discovered that the petitioners were the ones who did not follow the agreement as they continually held
    strikes and asked for an increase in salary. The Court of Industrial Relations was abolished during the
    pendency of the case and the case was transferred to the NLRC. The NLRC ruled that 86 out of the 136
    petitioners be reinstated in the position. The petitioners appealed which was subsequently denied. The
    petitioners then filed the same complaint to the Minister of Labor, Amado Inciong, who dismissed the
    complaint on the following grounds: 1) that the charge subject of the petition is barred by res judicata; 2)
    that petitioners’ cause of action had prescribed and that the same is now barred by laches; 3) that the
    corporate and distinct personality of respondent Inland was not successfully pierced.

    ISSUE:

    Whether or not the case is barred by res judicata

    HELD:

    Yes. For a prior judgment to constitute a bar to a subsequent case, the following requisites must concur:
    a) it must be a final judgment or order;

    (b) the court rendering the same must have jurisdiction over the subject matter and over the parties;

    (c) it must be a judgment or order on the merits, and

    (d) there must be between the two cases identity of parties, subject matter and cause of action.

    There is no question that the first three (3) requisites are present in this case.

    First, the decision in the first complaint had already become final and executory. The motion for
    reconsideration filed by the union in that case was denied and no petition was filed subsequent the denial.
    Thus, it became final and executory.

    Second, the CIR which rendered the decision had jurisdiction over the subject matter and over the
    parties.

    Third, the judgment rendered therein was a judgment on the merits of the case after the parties presented
    their evidence, oral and documented.

    Fourth, private respondents NLRC and then Deputy Minister Inciong did not commit any grave abuse of
    discretion amounting to lack of jurisdiction when they ruled that there is, between the first and the second
    complaints, identity of causes of action, subject matter and parties. Bringing the same action in the name
    of the individual members of the union will NOT take the case out of the ambit of the principle of Res
    judicata.

    The doctrine of res adjudicata applies not only to the decisions of regular courts but can be invoked even
    in administrative cases. It also applies to decisions of administrative bodies.
    When the union filed the first case, it was filing in behalf of the employees as the representative party. In
    effect, it is the same party. “While it is true that the complainants in the first charge was the union, in
    reality it had no material interest in the outcome of the case. The real party who stands to be benefited or
    defeated by a case brought in the name of the union are the union members themselves. Since the
    judgment therein had become final and executory, the subsequent filing of another ULP charge against
    the employer for the same violations committed during its existence, is barred by res judicata.” “The
    bringing of the same action in the name of the individual members of the union will not take out the case
    from the ambit of the principle of res judicata.” So, it is still the same parties.

    Note: The NLRC is a quasi-judicial body under DOLE that is tasked to promote and maintain
    industrial peace by resolving labor and management disputes.

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