GR 162868; (July, 2008) (Digest)
G.R. No. 162868 ; July 14, 2008
RODOLFO D. GARCIA, Petitioner, vs. PHILIPPINE AIRLINES and/or CRISTINA W. TRINIDAD, Manager, Catering Operations, Respondents.
FACTS
Petitioner Rodolfo D. Garcia was assigned by Stellar Industrial Services, Inc. to perform janitorial services for respondent Philippine Airlines (PAL) from 1976. In 1990, PAL requested his replacement from Stellar due to alleged poor performance and selling cigarettes on duty. Following an explanation from Garcia, Stellar terminated his employment. Garcia subsequently filed a complaint for illegal dismissal against both Stellar and PAL.
Crucially, prior to this illegal dismissal case, Garcia was among the Stellar employees who had filed a separate complaint for regularization against PAL in 1988. That prior case, which squarely raised the issue of whether Garcia was PAL’s employee, culminated in a final NLRC ruling that declared the complainants, including Garcia, to be employees of Stellar, not PAL. This NLRC decision attained finality after the Supreme Court denied the appeal.
ISSUE
Whether the doctrine of res judicata bars the re-litigation of the issue concerning the identity of Garcia’s employer in his illegal dismissal case against PAL.
RULING
Yes, res judicata applies. The Supreme Court affirmed the Court of Appeals’ decision absolving PAL, ruling that the issue of employer identity was already conclusively settled in the prior regularization case. For res judicata to apply, four elements must concur: (1) the former judgment must be final; (2) it must have been rendered by a court with jurisdiction; (3) it must be a judgment on the merits; and (4) there must be identity of parties, subject matter, and causes of action between the first and second actions.
All these elements are present. The NLRC decision in the regularization case became final and executory. The labor tribunals had jurisdiction over the subject matter. The judgment was on the merits, determining the employer-employee relationship. Finally, there is identity of parties (Garcia and PAL), subject matter (the nature of Garcia’s engagement with PAL), and causes of action (both cases fundamentally hinge on establishing an employer-employee relationship with PAL to claim rights therefrom). The Court emphasized that public policy demands an end to litigation to prevent vexing a party twice for the same cause. Since the prior final judgment definitively held Stellar as Garcia’s employer, he cannot now relitigate that issue to hold PAL liable for his dismissal.