GR 113448; (July, 1995) (Digest)
G.R. No. 113448 July 14, 1995
DANILO Q. MILITANTE, ET AL., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, GOLDEN TAXI CAB COMPANY, LORENZO ZAMORA, DOÑA NENA ZAMORA and DOÑA PACING ZAMORA, respondents.
FACTS
The petitioners, numerous taxi drivers, filed consolidated complaints against Golden Taxi Cab Company and its owners for illegal dismissal, non-payment of retirement benefits, and various monetary claims. These claims arose from the company’s closure. A prior case (NLRC NCR CA No. 003194-92) had already been filed by the Golden Taxi Employees Workers Union-ANGLO (GTEWU-ANGLO), the certified exclusive bargaining agent, which secured an award of financial assistance for its members affected by the closure. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the petitioners’ complaints for illegal dismissal, ruling that the principle of res judicata barred the action since the prior judgment, obtained by their exclusive bargaining representative, was binding on all employees in the bargaining unit.
ISSUE
The core issue is whether the petitioners’ complaint for illegal dismissal is barred by res judicata due to the prior judgment in a case filed by their certified exclusive bargaining agent.
RULING
The Supreme Court dismissed the petition, upholding the NLRC’s application of res judicata to the illegal dismissal claim. The Court deferred to the factual findings of the Labor Arbiter and NLRC, which were supported by substantial evidence, noting that quasi-judicial agencies’ expertise merits respect. Legally, the Court anchored its decision on Article 255 of the Labor Code, which designates the majority union as the exclusive representative of all employees in the unit for collective bargaining. Since GTEWU-ANGLO was the certified agent, its prior case for financial assistance due to the closure represented all unit members, including the petitioners. Therefore, the final judgment in that case, involving the same parties and cause of action concerning the closure’s effects, precluded a subsequent suit on the same claim. However, the Court clarified that the petitioners’ unresolved monetary claims—such as for non-remittance of SSS deductions, holiday pay, and thirteenth-month pay—were not barred, as these were neither raised nor adjudicated in the prior union case. The dismissal was thus without prejudice to pursuing these separate money claims before the Labor Arbiter.