G.R. No. 157696 -97 ; February 9, 2006
MARICALUM MINING CORPORATION, Petitioner, vs. HON. ARTURO D. BRION in his official capacity as Acting Secretary of Labor and Employment and the NATIONAL MINES AND ALLIED WORKERS UNION (NAMAWU Local 103), Respondents.

FACTS

Maricalum Mining Corporation (MMC) and the National Mines and Allied Workers Union (NAMAWU) were engaged in collective bargaining negotiations. During these negotiations, MMC dismissed and laid off workers in May and October 1996. NAMAWU filed notices of strike for unfair labor practice. The Secretary of Labor assumed jurisdiction over the dispute. In a 1997 order, Secretary Quisumbing ruled the layoffs were illegal, found MMC guilty of unfair labor practice, and ordered reinstatement with backwages and a new CBA. MMC’s motion for reconsideration led Secretary Trajano to issue a 1998 order modifying the prior ruling by setting aside the unfair labor practice finding and deleting the backwages award, remanding those issues to the NLRC for a hearing.
MMC filed a petition for certiorari with the Supreme Court (G.R. No. 133519) assailing these DOLE orders. The Court dismissed the petition in a 1998 Resolution, finding no grave abuse of discretion in Secretary Quisumbing’s original order. This Resolution became final. Meanwhile, the Labor Arbiter in a separate illegal dismissal case filed by an individual employee, Pedro Abuana, ruled the same retrenchments were legal, a decision which became final. MMC later filed the present petition, arguing the final Abuana case ruling should govern the dispute with the union.

ISSUE

Whether the final and executory decision in the individual illegal dismissal case (Abuana case) constitutes res judicata and should bar the implementation of the Secretary of Labor’s orders in the certified labor dispute involving the union.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The legal logic is anchored on the distinct nature and parties of the two proceedings. The Abuana case was an individual complaint for illegal dismissal adjudicated by the Labor Arbiter and the NLRC. In contrast, the case before the DOLE Secretary involved a certified labor dispute, a collective bargaining deadlock with notices of strike, over which the Secretary exercised compulsory arbitration powers under Article 263(g) of the Labor Code. The parties were also different: Abuana sued in his personal capacity, while the DOLE case was between MMC and the union, NAMAWU, representing the collective interest of the bargaining unit.
Consequently, the principle of res judicata does not apply. The causes of action and the relief sought were not identical. The individual case determined the legality of a specific employee’s dismissal. The certified case resolved the broader issues of unfair labor practice, bad faith bargaining, and the economic terms of a CBA affecting the entire bargaining unit. The Court further held that the finality of the Supreme Court’s 1998 Resolution in G.R. No. 133519, which sustained the Secretary’s assumption of jurisdiction and the core directives of the Quisumbing order, rendered the present petition an impermissible attempt to re-litigate settled matters.