GR L 31503; (August, 1974) (Digest)
G.R. No. L-31503 August 15, 1974
FEATI UNIVERSITY FACULTY CLUB (PAFLU), petitioner, vs. FEATI UNIVERSITY and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The petitioner, FEATI University Faculty Club, declared a strike on February 18, 1963, alleging the university’s unfair labor practice for refusal to bargain. The President certified the dispute to the Court of Industrial Relations (CIR). The CIR issued a return-to-work order on March 30, 1963. The university challenged various CIR orders, culminating in this Court’s December 27, 1966 decision, which affirmed the CIR’s jurisdiction, upheld the presidential certification, and recognized the faculty members as employees with the right to unionize. The 1966 decision became final.
Subsequently, the CIR, in an order dated February 7, 1969, directed the execution of the 1963 return-to-work order and awarded backwages. However, in a decision dated November 24, 1969, the same CIR reversed itself. It declared the 1963 strike illegal based on alleged acts of violence and coercion by the strikers, thereby nullifying the return-to-work order and the award for backwages. The faculty club assailed this 1969 decision for repudiating the final and executory 1966 judgment of the Supreme Court.
ISSUE
Whether the Court of Industrial Relations acted with grave abuse of discretion in rendering its November 24, 1969 decision, which effectively set aside its earlier orders that had been affirmed by a final judgment of the Supreme Court.
RULING
Yes. The Supreme Court reversed the CIR’s November 24, 1969 decision. The legal logic is anchored on the doctrine of res judicata. The factual findings, conclusions, and orders from the prior CIR proceedings, which were the subject of the Supreme Court’s definitive December 27, 1966 judgment, are now conclusive and immutable. The 1966 decision settled core issues: the CIR’s jurisdiction, the validity of the presidential certification, the employee status of the faculty, and their right to strike. The CIR is barred from reopening or nullifying these settled matters.
The CIR’s attempt to retroactively declare the 1963 strike illegal in its 1969 decision constitutes a collateral attack on a final judgment. The Supreme Court found this later decision devoid of factual and legal basis, as it sought to undo what had already been conclusively adjudicated. The CIR’s February 7, 1969 order for execution of the return-to-work directive was a logical consequence of the final 1966 ruling and could not be lawfully overturned on the merits of the same dispute. The case was remanded to the CIR with instructions to proceed with deliberate dispatch to resolve the remaining terms and conditions of employment under the certified dispute.