GR 147593; (July, 2006) (Digest)
G.R. No. 147593. July 31, 2006. GERONIMO Q. QUADRA, petitioner, vs. THE COURT OF APPEALS and the PHILIPPINE CHARITY SWEEPSTAKES OFFICE, respondents.
FACTS
Petitioner Geronimo Q. Quadra, then Chief Legal Officer of respondent Philippine Charity Sweepstakes Office (PCSO), was dismissed in July 1965 following a Civil Service Commission decision finding him administratively liable. Quadra, an active union organizer, subsequently filed an unfair labor practice case before the Court of Industrial Relations (CIR). In a 1966 decision, the CIR declared PCSO guilty of unfair labor practice, ordering Quadra’s reinstatement with full backwages, which PCSO complied with but appealed to the Supreme Court.
During the pendency of that appeal, and after the Supreme Court’s January 1967 ruling in Rheem of the Philippines, Inc. v. Ferrer recognized CIR jurisdiction over damage claims incidental to dismissal, Quadra filed a separate “Petition for Damages” with the CIR for moral and exemplary damages arising from his illegal dismissal. PCSO moved to dismiss, arguing lack of jurisdiction, splitting a cause of action, and lack of valid cause. The case eventually reached the Labor Arbiter and NLRC, which awarded Quadra P1.6 million in damages. The Court of Appeals reversed, holding the dismissal was not in bad faith as it followed a Civil Service Commission ruling, and that the damage claim constituted splitting of a cause of action.
ISSUE
Whether the Court of Appeals erred in: (1) ruling that PCSO did not act in bad faith, contrary to the final CIR decision finding unfair labor practice; and (2) holding that Quadra’s claim for damages amounted to splitting a cause of action.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the NLRC decision awarding damages. On the first issue, the Court held that the finding of unfair labor practice by the CIR, which had become final and executory, conclusively established that the dismissal was unlawful and tainted with bad faith. The CIR specifically found that Quadra was dismissed due to his union activities, a discriminatory act constituting unfair labor practice. This final judgment could no longer be contradicted by the Court of Appeals’ finding of an absence of bad faith. Unfair labor practice, being a violation of constitutional rights, inherently justifies an award of moral and exemplary damages to vindicate the employee’s rights and serve as a deterrent.
On the second issue, the Court ruled that Quadra’s filing of the damage petition did not constitute splitting a cause of action. At the time the original unfair labor practice case was filed, prevailing jurisprudence held that the CIR had no jurisdiction to award damages. It was only in Rheem (January 1967) that the Court recognized such jurisdiction. Quadra filed his damage claim promptly after this new ruling and before the CIR decision on the main case became final. Therefore, he could not have included the damage claim in his initial complaint, and his subsequent filing was a proper invocation of a newly recognized remedy, not a splitting of a single cause of action.