GR 157320; (June, 2005) (Digest)
G.R. No. 157320; June 28, 2005
Kabankalan Catholic College, petitioner, vs. Kabankalan Catholic College Union-PACIWU-TUCP, respondent.
FACTS
Kabankalan Catholic College (KCC) and the respondent Union reached a deadlock in CBA negotiations in 1998, prompting the Secretary of Labor to assume jurisdiction. The Secretary issued a Decision on January 4, 1999, awarding wage increases and ordering the parties to execute a CBA, which was later modified by a Resolution on April 12, 1999. KCC challenged this Decision via a petition for certiorari (G.R. No. 139216), arguing the Union lacked legal personality. The Supreme Court dismissed this petition in 1999 due to late filing and payment, a dismissal which became final. Subsequently, the Labor Secretary issued orders for the execution of the 1999 arbitral award.
KCC again resisted execution, filing a petition with the Court of Appeals (CA) to quash the writ, persistently contending that the Union was not a legitimate labor organization. The CA, however, ruled against KCC. It quashed the specific writ for procedural reasons but ordered the Labor Secretary to issue an alias writ to enforce the 1999 Decision, including the directive for the parties to conclude a CBA. KCC elevated the case to the Supreme Court.
ISSUE
Whether the respondent Union possesses the legal personality to be a party to a Collective Bargaining Agreement with the petitioner.
RULING
Yes. The Supreme Court denied KCC’s petition and affirmed the CA. The core legal principle applied is the “law of the case” doctrine. The issue of the Union’s legitimacy was conclusively settled in the prior proceedings before the Secretary of Labor, whose April 12, 1999 Resolution explicitly found the Union to be a legitimate labor organization based on its Certificate of Creation as a local chapter. KCC’s direct challenge to that finding via G.R. No. 139216 was dismissed by the Supreme Court, and that dismissal attained finality. Consequently, the finding on the Union’s legal status has become immutable and binding between the parties. KCC is now barred from re-litigating this identical issue in a subsequent proceeding, as it constitutes a collateral attack on a final judgment. The Court emphasized that final judgments must not be disturbed, and the Union’s legitimacy, having been upheld in the final arbitral award, is a settled matter that KCC must respect.