GR 172890; (April, 2008) (Digest)
G.R. No. 172890; April 30, 2008
S.L. TEVES, INC./HACIENDA NUESTRA SENORA DEL PILAR, AND/OR RICARDO M. TEVES, As President AND VICENTE M. TEVES, as General Manager, petitioners, vs. CASIANO ERAN, respondent.
FACTS
Respondent Casiano Eran worked as a laborer for petitioners since 1978. On November 22, 2001, he was informed by a “cabo” that his services were terminated. He filed an illegal dismissal complaint. On March 18, 2002, after receiving P175.00 from petitioners, Eran withdrew this first complaint. The Labor Arbiter dismissed the case “with prejudice.”
Subsequently, on September 2, 2002, Eran filed a second complaint for illegal dismissal and monetary claims. The Labor Arbiter dismissed this second complaint, applying the principle of res judicata based on the prior dismissal “with prejudice.” The NLRC affirmed. The Court of Appeals reversed, finding Eran to be a regular employee who was illegally dismissed, and ordered his reinstatement with monetary claims.
ISSUE
Whether the principle of res judicata bars the second illegal dismissal complaint.
RULING
No, res judicata does not apply. For res judicata to bar a subsequent action, the judgment in the prior case must be a judgment on the merits. The Supreme Court affirmed the Court of Appeals, holding that the dismissal of the first complaint was not a judgment on the merits. The Labor Arbiter’s March 18, 2002 Order was based solely on Eran’s withdrawal of the complaint upon receiving P175.00. The receipt only proved payment for four days of work; it did not constitute an admission by Eran that he was not an employee or that he voluntarily withdrew his claim. The Labor Arbiter in the second case explicitly refused to discuss the merits, relying only on the prior order.
The petitioners’ argument that Eran admitted working without their knowledge is unsupported by evidence. Since the dismissal of the first case was not an adjudication on the merits, the requisites for res judicata are not satisfied. The Supreme Court, in a Rule 45 petition, generally does not review factual findings. It found the Court of Appeals’ factual conclusions—that Eran was a regular employee illegally dismissed—to be supported by the evidence. The petition was denied.