GR 167945; (July, 2006) (Digest)
G.R. No. 167945 ; July 14, 2006
COMMANDER REALTY, INC., petitioner, vs. FREDDIE FERNANDEZ, et al., respondents.
FACTS
Respondents filed an Amended Petition before the Social Security Commission (SSC) against petitioner Commander Realty, Inc. (CRI). They alleged they were employees of CRI and that it failed to register with the SSS and remit their contributions, depriving them of benefits. They appended documents to support their employment claim and prayed for CRI’s compulsory registration and remittance of contributions. CRI, in its Answer, insisted respondents were not its employees. It narrated that its president, Wilhelmina Andrada, had engaged the services of contractor Simplicio Abiera for construction projects on her personal properties, and that CRI had no participation in the selection or hiring of the workers.
Simultaneously, respondents had filed labor cases for illegal dismissal and monetary claims against CRI and Andrada before the National Labor Relations Commission (NLRC). The Labor Arbiter dismissed those complaints, ruling no employer-employee relationship existed between CRI and respondents. This ruling was affirmed by the NLRC and the Court of Appeals. The Supreme Court subsequently denied respondents’ petition in G.R. No. 164399, with finality. Despite this, the SSC proceeded and ruled in favor of respondents, ordering CRI to register and remit SSS contributions. The CA affirmed the SSC’s decision.
ISSUE
Whether the doctrine of res judicata bars the SSC case filed by respondents.
RULING
Yes, res judicata applies. The Supreme Court granted CRI’s petition, reversing the CA. The elements of res judicata are present: a final former judgment (the NLRC case culminating in the Supreme Court’s denial in G.R. No. 164399), a court of competent jurisdiction (the Labor Arbiter/NLRC, which has jurisdiction over employer-employee relationships), and identity of parties, subject matter, and causes of action. The central issue in both the labor case and the SSC case is identical: whether an employer-employee relationship existed between CRI and respondents. A change in the form of the action (from labor claims to SSS coverage) or the relief sought does not negate the application of res judicata where the parties are litigating the same fundamental issue. The Court’s final ruling in the labor case that no such relationship existed is conclusive and binding. The SSC and the CA erred in disregarding this final judgment.