Primary Holding
A final and executory judgment bars a party from relitigating the same compromise agreements in a different forum, and the Court of Appeals may not reverse the NLRC's factual finding that amounts paid under those agreements were merely advance or partial payments when that finding is supported by substantial evidence. Willful and deliberate forum shopping exists where a party pursues simultaneous remedies in the Supreme Court and the Court of Appeals asserting the same rights and reliefs based on the same compromise agreements, without disclosing the pendency of the other case.
Background
Petitioners Orlando Rodriguez and Daryl Rama were among the complainants in an illegal dismissal case against their employer, San Roque Metals, Inc. (SRMI). Their money claims were adjudicated in the labor tribunals and affirmed in CA-G.R. SP No. 05614-MIN, while SRMI's attempt to challenge that affirmance reached the Supreme Court in G.R. No. 226574. The present dispute arises from the execution stage of those final labor awards, where SRMI relied on quitclaim and compromise agreements it had executed with Rodriguez and Rama. The case also involves the statutory and procedural rules on execution of judgments, compromise agreements, and forum shopping.
History
2011 – 2024-
Mar 30, 2011
Rodriguez, Rama, and three other complainants filed an illegal dismissal complaint against SRMI.
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9 mos 25 days later
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Jan 24, 2012
ELA Henry F. Te dismissed the illegal dismissal complaint but ordered SRMI to pay Rodriguez, Rama, and Jeffrey Adiong 13th month pay and service incentive leave.
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11 mos 4 days later
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Dec 28, 2012
The NLRC dismissed SRMI's partial appeal and partly granted the complainants' appeal, declared Adiong, Rodriguez, and Rama regular employees, ordered payment of backwages and benefits, and declared Rama's Quitclaim invalid but without prejudice to crediting PHP 20,000.
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2 mos 27 days later
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Mar 27, 2013
The NLRC denied SRMI's motion for reconsideration.
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2 yrs 2 mos later
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Jun 24, 2015
The CA dismissed SRMI's petition for certiorari in CA-G.R. SP No. 05614-MIN.
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1 yr 2 mos later
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Sep 9, 2016
SRMI filed a petition for review on certiorari in G.R. No. 226574, arguing that the CA erred in disregarding Rama's Quitclaim and Rodriguez's Compromise Agreement.
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40 days later
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Oct 19, 2016
The Supreme Court denied SRMI's petition for review for being filed beyond the 15-day reglementary period under Rule 45, Section 2, in relation to Rule 56, Section 5(a).
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8 mos 11 days later
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Jun 30, 2017
ELA Dayot issued an Order granting execution and computing awards: Adiong PHP 390,214.15; Rodriguez PHP 235,046.02; Rama PHP 398,786.31; total PHP 1,024,046.48, with no 5% withholding tax and a writ of execution for partial satisfaction.
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2 mos 28 days later
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Sep 27, 2017
The NLRC denied SRMI's Petition for Extraordinary Remedies and affirmed the June 30, 2017 Order.
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5 mos 1 day later
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Feb 28, 2018
The NLRC denied SRMI's motion for reconsideration.
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58 days later
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Apr 27, 2018
SRMI filed a petition for certiorari with the CA, docketed as CA-G.R. SP No. 08711-MIN.
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1 yr later
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Apr 30, 2019
The CA granted SRMI's petition, set aside the NLRC Resolutions, and held the Compromise Agreements valid and controlling.
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34 days later
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Jun 3, 2019
The Supreme Court denied SRMI's motion for reconsideration in G.R. No. 226574 and noted without action its Manifestation, stating that no relief could be granted in relation to the compromise agreements.
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1 yr 2 mos later
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Aug 25, 2020
The CA denied Rodriguez and Rama's motion for reconsideration.
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3 mos 24 days later
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Dec 19, 2020
Rodriguez and Rama filed the present Petition for Review on Certiorari with the Supreme Court.
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3 yrs 8 mos later
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Aug 19, 2024
The Supreme Court granted the petition, reversed the CA, remanded the case for recomputation with 6% legal interest, and directed SRMI and its counsel to show cause why they should not be held in direct contempt.
Facts
Rodriguez and Rama, together with three other complainants, filed a complaint for illegal dismissal against SRMI on March 30, 2011. In a Decision dated January 24, 2012, Executive Labor Arbiter Henry F. Te dismissed the illegal dismissal complaint but ordered SRMI to pay Rodriguez, Rama, and Jeffrey Adiong certain sums corresponding to their 13th month pay and service incentive leave. Rama then executed a Quitclaim and Release with Motion to Dismiss dated March 12, 2012, in consideration of PHP 20,000, waiving any claim or right of action against SRMI; the other complainants executed similar documents. SRMI filed a Memorandum of Partial Appeal with the NLRC on March 27, 2012, while Rodriguez and Rama, with the other complainants, also filed a Memorandum of Appeal. In a Resolution dated December 28, 2012, the NLRC dismissed SRMI's partial appeal and partly granted the appeal of Adiong, Rodriguez, and Rama, declaring them regular employees of SRMI and ordering SRMI to pay them backwages plus allowances and other benefits; the award was without prejudice to crediting the PHP 20,000 Rama had received under the Quitclaim, which the NLRC declared invalid. The NLRC denied SRMI's motion for reconsideration in its Resolution dated March 27, 2013, prompting SRMI to file a petition for certiorari with the CA, docketed as CA-G.R. SP No. 05614-MIN.
While CA-G.R. SP No. 05614-MIN was pending, SRMI entered into separate Compromise Agreements with Rodriguez and Rama dated February 3, 2015 and April 22, 2015, respectively. These Agreements were also acknowledged by Executive Labor Arbiter Dayot. The CA dismissed SRMI's petition in its June 24, 2015 Decision. On June 30, 2015, SRMI filed a Manifestation informing the CA that it had entered into a Compromise Agreement with Rodriguez. SRMI's motion for reconsideration was denied. On September 9, 2016, SRMI filed a petition for review on certiorari with the Supreme Court, docketed as G.R. No. 226574, arguing that the CA erred in disregarding the Quitclaim executed by Rama and the Compromise Agreement signed by Rodriguez. In a Resolution dated October 19, 2016, the Supreme Court denied SRMI's petition for review for having been filed beyond the reglementary period of 15 days under Rule 45, Section 2, in relation to Rule 56, Section 5(a) of the Rules of Court. SRMI then filed a Manifestation dated February 24, 2017, praying for dismissal of Rodriguez and Rama's complaints with finality in view of the Compromise Agreements, and a motion for reconsideration dated March 27, 2017. In a Resolution dated June 28, 2017, the Supreme Court noted and granted SRMI's Manifestation and the withdrawal of appearance of its previous counsel, and ordered Rodriguez and Rama to comment on SRMI's motion for reconsideration. Rodriguez and Rama filed their Comment/Opposition, SRMI filed a Comment, and Rodriguez and Rama filed a Reply. In a Resolution dated June 3, 2019, the Supreme Court denied SRMI's motion for reconsideration and noted without action SRMI's Manifestation, explaining that the Labor Arbiter and the NLRC had deemed the amounts paid under the compromise agreements as advance or partial payments of respondents' total monetary claims, and that no relief could be granted to SRMI in relation to said compromise agreements.
Meanwhile, Rodriguez and Rama, with three other complainants, filed a Motion for the Issuance of Writ of Execution with Prayer for Recomputation of the Judgment Award with the NLRC-RAB XIII, Butuan City. They sought execution of the NLRC's judgment awards, as affirmed by the CA in CA-G.R. SP No. 05614-MIN. On June 30, 2017, the NLRC-RAB XIII, through ELA Dayot, issued an Order directing SR Metals Inc. to pay the complainants their monetary awards: Jeffrey Adiong PHP 390,214.15; Orlando Rodriguez PHP 235,046.02; and Daryl Rama PHP 398,786.31, for a total of PHP 1,024,046.48. The Order stated that since the complainants were minimum wage earners, their monetary awards were not subject to 5% withholding tax pursuant to Republic Act No. 9504, BIR Revenue Regulation No. 10-2008 dated July 8, 2008, as restated in NLRC Memorandum Circular No. 90-02, Series of 2013 (September 18, 2013), and directed the issuance of a writ of execution for the enforcement and partial satisfaction of the complainants' backwages, separation pay, and other monetary awards.
SRMI filed a Petition for Extraordinary Remedies before the NLRC, asserting that the Compromise Agreements executed by Rodriguez and Rama were valid and that the ELA erred in treating the amounts received by Rodriguez and Rama as advance payments rather than full settlement of their claims. On September 27, 2017, the NLRC issued a Resolution denying SRMI's petition and affirming the June 30, 2017 Order, and on February 28, 2018, the NLRC denied reconsideration. SRMI appealed the NLRC's Resolutions to the CA through a petition for certiorari dated April 27, 2018. In its assailed April 30, 2019 Decision, the CA granted SRMI's petition, set aside the NLRC Resolutions, and directed the NLRC to issue the appropriate resolution. The CA held that the Compromise Agreements were valid and controlling between Rodriguez and Rama and SRMI, reasoning that the terms were clear and unequivocal, that Rodriguez and Rama acknowledged receipt of the monetary consideration as full, complete, and final satisfaction of their claims, that they had no further claims, and that they released SRMI from liability. The CA also stressed that Rodriguez and Rama did not deny having executed the Compromise Agreements, nor did they provide evidence of fraud, misrepresentation, or coercion; the Agreements were subscribed and sworn to before ELA Dayot, so it could not be said that they did not voluntarily agree or were unaware of the legalities. The CA denied Rodriguez and Rama's motion for reconsideration.
The ELA had stated that Rodriguez and Rama were informed that the amounts they were to receive under the Compromise Agreements were only advance payments, subject to the final disposition of their complaints against SRMI. Specifically, the ELA held that Rama's PHP 20,000 under the March 12, 2012 Compromise Settlement and PHP 30,000 under the February 3, 2015 Compromise Agreement, totaling PHP 50,000, were advance payments; Rodriguez's PHP 70,000 under the April 22, 2015 Compromise Agreement was likewise treated as partial payment. These amounts were made known to the parties during the pre-execution conference as being without prejudice to the final disposition of the case pending with the Supreme Court. The NLRC, in turn, found that the monetary considerations given to Rodriguez and Rama were unreasonable and declared the Compromise Agreements invalid: Rama received PHP 50,000 against a judgment award of PHP 412,533.01, or 12.12%, while Rodriguez received PHP 70,000 against a judgment award of PHP 383,678.20, or 18.24%. The NLRC cited Galicia vs. NLRC and Globe Paper Mills, where the Court deemed a quitclaim consideration inordinately low and exceedingly unreasonable relative to the award, and held that the workers accepted the offer knowing it to be unjust and insufficient because of destitution caused by protracted unemployment. The NLRC ruled that the employer and employee did not stand on the same footing, that the case had dragged on for years, and that the private respondents were not in a position to resist the petitioner's offer, so they should not be estopped from claiming the full amount legally due them.
Arguments of the Petitioners
- Law of the Case: Petitioners argued that the CA's 2015 Decision in CA-G.R. SP No. 05614-MIN had clearly disposed of the issue of the compromise agreements entered into by respondents and SRMI, and had struck down the same compromise agreements as being unconscionable; the assailed CA Decision violated the law of the case, under which legal conclusions announced on the first appeal became the law of the case, whether correct on general principles or not, so long as the facts on which the decision was predicated continued to be the facts of the case before the court.
- Forum Shopping: Petitioners argued that SRMI violated the rule against forum shopping when it failed to inform the CA that, at the time it filed the petition for certiorari, SRMI still had a petition for review on certiorari pending with the Supreme Court (G.R. No. 225574).
Arguments of the Respondents
- No Substantial Question / Scope of Rule 45: SRMI countered that Rodriguez and Rama failed to present questions of substance as to warrant consideration for review under Rule 45; the Court's review of a CA ruling in a labor case is limited to ascertaining the correctness of the CA's decision in finding the presence or absence of grave abuse of discretion and deciding any other jurisdictional error that attended the CA's interpretation or application of the law, and the issues raised by Rodriguez and Rama are beyond the scope of a Rule 45 proceeding.
- Factual Issues: SRMI argued that Rodriguez and Rama raised factual issues which are not the proper subject of a Rule 45 proceeding.
- Law of the Case Inapplicable: SRMI argued that the doctrine of law of the case does not apply because the Court has yet to rule on the validity of the Compromise Agreements; the 2015 CA Decision cited by Rodriguez and Rama pertains only to the Quitclaim executed by Rama on March 12, 2012, and not to the Compromise Agreements.
- Validity of Compromise Agreements: SRMI maintained that the Compromise Agreements are valid and must remain the law between the parties.
- Forum Shopping Denied: SRMI argued that it only raised the issue of the validity of the compromise agreements in G.R. No. 226574 as these are supervening events, and G.R. No. 226574 and the present Petition involve different sets of facts and issues.
Issues
- Grave Abuse of Discretion / Treatment of Compromise Payments: Whether the CA erred in ruling that the NLRC committed grave abuse of discretion in treating the amounts received by Rodriguez and Rama under the Quitclaim and Compromise Agreements as advance or partial payments of their judgment awards rather than full settlement.
- Finality and Immutability of Judgment / Law of the Case: Whether the CA erred in granting SRMI relief based on the same Quitclaim and Compromise Agreements despite the final and executory denial of SRMI's petition in G.R. No. 226574, thereby circumventing the immutability of judgments.
- Forum Shopping: Whether SRMI committed willful and deliberate forum shopping by pursuing simultaneous remedies before the Supreme Court and the CA based on the same Compromise Agreements.
Ruling
- Grave Abuse of Discretion / Treatment of Compromise Payments: Yes. The CA erred in ruling that the NLRC committed grave abuse of discretion; the NLRC's treatment of the amounts as advance or partial payments was supported by substantial evidence and the ELA's findings.
- Finality and Immutability of Judgment / Law of the Case: Yes. The CA erred in granting SRMI relief based on the same agreements despite the final and executory G.R. No. 226574 denial; immutability of judgments barred relitigation.
- Forum Shopping: Yes. SRMI committed willful and deliberate forum shopping by pursuing simultaneous remedies in G.R. No. 226574 and CA-G.R. SP No. 08711-MIN, asserting the same Compromise Agreements without disclosing the pending Supreme Court case.
Ruling Rationale
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Grave Abuse of Discretion / Treatment of Compromise Payments: Under Rule 65, judicial review of NLRC decisions is confined to issues of want or excess of jurisdiction and grave abuse of discretion; the CA is not to decide whether the NLRC's decision on the merits was correct. Grave abuse of discretion exists when the NLRC's findings and conclusions are not grounded on substantial evidence, which is such amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. In Arcilla vs. San Sebastian College-Recoletos, Manila, the Court explained that if the NLRC's ruling has basis in the evidence and the applicable law and jurisprudence, then no grave abuse of discretion exists and the CA should dismiss the petition. SRMI's liability for Rodriguez and Rama's illegal dismissal and money claims was already settled by the CA in CA-G.R. SP No. 05614-MIN, and that Decision and Resolution attained finality with the denial of SRMI's petition for review on certiorari in G.R. No. 226574. The issue before the Court was therefore not whether SRMI was correctly found liable, but whether the CA erred in ruling that the NLRC committed grave abuse of discretion in treating the amounts received by Rodriguez and Rama under the Compromise Agreements as merely advance payments made prior to the execution of the judgment awards in their favor. Rodriguez and Rama executed a total of three agreements with SRMI: first, the Quitclaim and Release with Motion to Dismiss signed by Rama and dated March 12, 2012; second, the Compromise Agreement dated February 3, 2015, also signed by Rama; and third, the Compromise Agreement dated April 22, 2015 and signed by Rodriguez. In its 2015 Decision, the CA affirmed the NLRC's finding that the Quitclaim executed by Rama was invalid, and this ruling became final with the denial of SRMI's petition for review on certiorari in G.R. No. 226574. In contrast, neither the CA nor this Court has ruled on the validity of the Compromise Agreements. However, SRMI already repeatedly raised the existence of the Quitclaim and the Compromise Agreements before the CA in CA-G.R. SP No. 05614-MIN, and before this Court in its petition for review on certiorari in G.R. No. 226574. One of SRMI's main contentions in its petition in G.R. No. 226574 was that the CA erred in affirming the NLRC, considering that Rama had executed the Quitclaim and Rodriguez had executed a Compromise Agreement with SRMI. SRMI also cited the Compromise Agreements in its Manifestation dated February 24, 2017, which the Court noted without action in its Resolution dated June 3, 2019 in G.R. No. 226574, and in its Comment. Despite the foregoing, SRMI also raised the existence of the Compromise Agreements before the ELA during the execution process. While the ELA and NLRC held that the amounts received by Rodriguez and Rama under the Quitclaim and Compromise Agreements were merely partial payments of SRMI's liability, the CA reversed the NLRC and held that the Compromise Agreements constituted the law between the parties. As a result, the same Quitclaim and Compromise Agreements cited by SRMI in G.R. No. 226574 were again before this Court. By raising the same issues before the labor tribunals during the execution process and eventually before the CA, what SRMI truly sought was the reversal of the Court's final and executory Resolution denying its appeal in G.R. No. 226574. In granting SRMI's petition for certiorari, the CA allowed SRMI to circumvent the finality of the Court's Resolution in G.R. No. 226574, ignoring the principle of immutability of judgments. The Court's admonition in Heirs of Pidacan vs. Air Transportation Office is apropos: execution is the fruit and the end of the suit and is the life of the law; a judgment, if left unexecuted, would be nothing but an empty victory for the prevailing party; litigation must end sometime and somewhere; an effective and efficient administration of justice requires that once a judgment has become final, the winning party be not deprived of the fruits of the verdict; courts must guard against any scheme calculated to bring about that result. By repeatedly attempting to evade payment of Rodriguez and Rama's claims and refusing to accept the Court's denial of its petition for review on certiorari in G.R. No. 226574, SRMI has, for years, deprived petitioners of their right to enjoy the finality of the CA's 2015 Decision and the monetary awards computed by the ELA in his June 30, 2017 Order. The CA also erred in reversing the NLRC's factual findings. Factual findings of labor officials exercising quasi-judicial functions are accorded great respect and even finality by the courts when the findings are supported by substantial evidence. Questions of fact are for the labor tribunals to resolve and are binding upon this Court unless there is a showing of grave abuse of discretion or that they were arrived at arbitrarily or in utter disregard of the evidence on record. Lanao Del Sur Electric Cooperative vs. LASURECO Employees Union-All Workers Alliance Trade Union involved a dispute arising from an order issued by the NLRC during the execution process; similar to the instant controversy, one of the arguments raised by the petitioner employer was that the NLRC erred in failing to consider alleged partial payments the petitioner had made to its employees in computing the total judgment award for execution. The Court rejected the petitioner's arguments, ruling that the issue of whether the NLRC erred when it failed to consider the evidence submitted by LASURECO, which shows that the payment received by the Union is a total settlement of all its claims, is a question of fact which is improper in a Rule 45 petition; the findings of fact of quasi-judicial agencies such as those of the NLRC must be accorded great respect and even finality when supported by substantial evidence; such factual findings may only be reviewed, reversed, or modified by the courts when the labor tribunals commit grave abuse of discretion. Here, ELA Dayot stated that Rodriguez and Rama were informed that the amounts they were to receive under the Compromise Agreements were only advance payments, subject to the final disposition of their complaints against SRMI. The ELA held that Rama's PHP 20,000 under the March 12, 2012 Compromise Settlement and PHP 30,000 under the February 3, 2015 Compromise Agreement, totaling PHP 50,000, were advance payments; Rodriguez's PHP 70,000 under the April 22, 2015 Compromise Agreement was likewise treated as partial payment, as these were made known to the parties during the pre-execution conference that the amount received by the individual complainants shall be without prejudice to the final disposition of the case pending with the Supreme Court. It bears emphasis that it was also ELA Dayot who acknowledged the execution of the Compromise Agreements. Accordingly, the ELA's findings as to the true nature of the Compromise Agreements and the parties' intent in signing the Agreements should not be lightly set aside. In resolving SRMI's Petition for Extraordinary Remedies, the NLRC cited the above findings of the ELA. The NLRC also found that the monetary considerations given to Rodriguez and Rama were unreasonable and declared the Compromise Agreements invalid. The Court has given effect to quitclaims in certain cases if the employer is able to prove the following requisites: (1) the employee executes a deed of quitclaim voluntarily; (2) there is no fraud or deceit on the part of any of the parties; (3) the consideration of the quitclaim is credible and reasonable; and (4) the contract is not contrary to law, public order, public policy, morals or good customs, or prejudicial to a third person with a right recognized by law. In the instant case, the reasonableness of the amounts received by the respondents was questionable: Rama received PHP 50,000 against a judgment award of PHP 412,533.01, or 12.12%; Rodriguez received PHP 70,000 against a judgment award of PHP 383,678.20, or 18.24%. The NLRC found the ruling in Galicia vs. NLRC and Globe Paper Mills relevant because the amount accepted by petitioners therein was also very much less than the amount awarded by the Labor Arbiter; in said case, the Court deemed the consideration for the quitclaim of PHP 12,000 per worker and the total sum of PHP 300,000 as inordinately low and exceedingly unreasonable relative to the PHP 107,380 per worker and total PHP 3,223,261 awarded by the Arbiter; the workers decided to accept the offer knowing the same to be unjust and insufficient compared to their just claims because of destitution caused by their protracted unemployment; the Court held the consideration palpably inequitable and thus the quitclaim was not considered an obstacle to the pursuit of their legitimate claims. In the same manner, the NLRC ruled that the amount received by each of the private respondents was inequitably below what they were rightfully entitled; the employer and the employee do not stand on the same footing; the case having dragged on for years, the private respondents were not in a position to resist petitioner's offer, even if the same was obviously inequitable compared to what they were entitled; such being the case, they should not be estopped from claiming the full amount of what they are legally entitled. Despite the foregoing, the CA ignored the factual findings of the ELA and NLRC and reversed the latter based solely on their limited analysis of the text of the Compromise Agreements. The CA ruled that the terms of the Compromise Agreements were clear and unequivocal; Rodriguez and Rama acknowledged receipt of the monetary consideration as the full, complete and final satisfaction of their claims against SRMI; they agreed that, by accepting the monetary considerations, they had no further claims, rights or actions of whatever nature against SRMI, whether past, present or contingent; and they further agreed that they "forever release, remiss, and discharge SRMI and its subsidiaries, directors, stockholders, officers, successors-in-interest from any liability or claims arising from or in relation to [their] labor complaint against SRMI." The CA also emphasized that the Compromise Agreements were executed in the presence of ELA Dayot, who is presumed to have explained the terms of the Agreements to them; the Agreements were subscribed and sworn to before ELA Dayot; they were executed after the NLRC rendered a favorable decision to Rodriguez and Rama and while an appeal was pending before this Court; it could not be said that Rodriguez and Rama did not give their individual assent thereto when they affixed their signatures; and it could not be said that they were unaware of the binding effects and legalities of executing the Compromise Agreements, since these agreements were executed in the presence of ELA Dayot; thus, having been executed in the presence of ELA Dayot, it is presumed that ELA Dayot ensured that Rodriguez and Rama fully understood the terms and conditions embodied in the Compromise Agreements. The CA's conclusion is surprising, considering ELA Dayot's categorical statement that Rodriguez and Rama were informed that the amounts they received under the Quitclaim and Compromise Agreements were merely partial payments. In the face of this unequivocal statement—which the CA chose to ignore—the CA's "presumption" that ELA Dayot "ensured that Rodriguez and Rama fully understood the terms and conditions embodied in the Compromise Agreements" has no basis. In sum, the CA erred in ruling that the NLRC committed grave abuse of discretion. In so ruling, the CA acceded to SRMI's dilatory tactics and underhanded attempts to resurrect its lost appeal and substituted its own judgment for that of the ELA and NLRC based on a mere "presumption."
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Finality and Immutability of Judgment / Law of the Case: Once a judgment has become final, it becomes immutable and unalterable. It cannot be changed in any way, even if the modification is for the correction of a perceived error, by the court which promulgated it or by a higher court. Judgments and orders should be final at some definite time based on law, as there would be no end to litigation. While the losing party has a right to appeal his or her case, the winning party has an attendant right to enjoy the finality of the decision issued in his or her favor, through the execution process to satisfy the award given to him or her. The Court's Resolution in G.R. No. 226574 denying SRMI's petition for review on certiorari became final and executory. In that case, the Court expressly stated that no relief could be granted to SRMI in relation to the compromise agreements SRMI had executed with Rodriguez and Rama. The Court also ruled in G.R. No. 226574 that it cannot grant SRMI any relief in relation to the Compromise Agreements, considering that its petition for review on certiorari was dismissed for being filed out of time. This ruling has long become final and executory, and the principle of immutability of judgments prevents SRMI from seeking reliefs based on the very same Compromise Agreements before a different forum. To allow SRMI to do so would be tantamount to rewarding it for the belated filing of its petition for review on certiorari in G.R. No. 226574 as well as its manifest bad faith. Contrary to SRMI's misleading claims, the execution of the Compromise Agreements was not a "supervening event" in G.R. No. 226574. These Agreements were executed on February 3, 2015 and April 22, 2015, while CA-G.R. SP No. 05614-MIN was still pending before the CA and before SRMI filed its first motion for extension of time to file petition for review on certiorari in G.R. No. 226574 on August 17, 2016. In fact, SRMI cited the Compromise Agreement executed by Rodriguez in its petition. Accordingly, SRMI's claim that the execution of the Compromise Agreements was a "supervening event" in G.R. No. 226574 is downright false. In conclusion, SRMI had every opportunity to present its arguments regarding the Compromise Agreements in G.R. No. 226574, as indeed it did in the following: (a) its petition for review on certiorari; (b) Manifestation (With Prayer for Dismissal of Claims of Respondents by Reason of Execution of Valid Compromise Agreements) dated February 24, 2017; and (c) Comment (To the Respondents' Partial Motion for Reconsideration with Comment/Opposition to the Petitioner's Motion for Reconsideration). In choosing to repeat the very same arguments in CA-G.R. SP No. 08711-MIN, SRMI demonstrated an obstinate refusal to accept the outcome of CA-G.R. SP No. 05614-MIN and committed willful and deliberate forum shopping.
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Forum Shopping: The test for determining the existence of forum shopping is whether the elements of litis pendentia are present, or whether a final judgment in one case amounts to res judicata in another. There is forum shopping when the following elements are present: (a) identity of parties, or at least such parties as representing the same interests in both actions; (b) identity of rights asserted and reliefs prayed for, the relief being founded on the same facts; and (c) the identity of the two preceding particulars, such that any judgment rendered in the other action will, regardless of which party is successful, amount to res judicata in the action under consideration. In determining whether forum shopping exists, what is truly important is the vexation caused the courts and the parties by a party who asks different courts to rule on the same or related causes and/or to grant the same or substantially the same reliefs, creating the possibility of conflicting decisions upon the same issue. The justification for the prohibition against forum shopping is that a party should not be allowed to pursue simultaneous remedies in two different courts, as this constitutes abuse of court processes which tends to degrade the administration of justice. In this case, SRMI pursued simultaneous remedies before this Court (in G.R. No. 226574) and before the CA (in CA-G.R. SP No. 08711-MIN). In so doing, SRMI gravely abused court processes and violated the prohibition against forum shopping. First, there is identity of parties in the two cases, as both G.R. No. 226574 and the instant Petition (as well as the execution proceedings which preceded it) involve Rodriguez, Rama, and SRMI. Second, there is identity of rights asserted and reliefs prayed for, with SRMI asserting in both cases that it is absolved from liability due to the Compromise Agreements executed by Rodriguez and Rama. Moreover, SRMI filed its petition for certiorari in CA-G.R. SP No. 08711-MIN in 2018, when G.R. No. 226574 was still pending before this Court. However, SRMI did not inform the CA of the pendency of G.R. No. 226574. The Verification and Certification of Non-Forum Shopping attached to SRMI's petition for certiorari in CA-G.R. SP No. 08711-MIN states that SRMI "has not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency." Third, the Court already ruled in G.R. No. 226574 that it cannot grant SRMI any relief in relation to the Compromise Agreements, considering that its petition for review on certiorari was dismissed for being filed out of time. This ruling has long become final and executory, and the principle of immutability of judgments prevents SRMI from seeking reliefs based on the very same Compromise Agreements before a different forum. To allow SRMI to do so would be tantamount to rewarding it for the belated filing of its petition for review on certiorari in G.R. No. 226574 as well as its manifest bad faith. Contrary to SRMI's misleading claims, the execution of the Compromise Agreements was not a "supervening event" in G.R. No. 226574. These Agreements were executed on February 3, 2015 and April 22, 2015, while CA-G.R. SP No. 05614-MIN was still pending before the CA and before SRMI filed its first motion for extension of time to file petition for review on certiorari in G.R. No. 226574 on August 17, 2016. In fact, SRMI cited the Compromise Agreement executed by Rodriguez in its petition. Accordingly, SRMI's claim that the execution of the Compromise Agreements was a "supervening event" in G.R. No. 226574 is downright false. In conclusion, SRMI had every opportunity to present its arguments regarding the Compromise Agreements in G.R. No. 226574, as indeed it did in the following: (a) its petition for review on certiorari; (b) Manifestation dated February 24, 2017; and (c) Comment. In choosing to repeat the very same arguments in CA-G.R. SP No. 08711-MIN, SRMI demonstrated an obstinate refusal to accept the outcome of CA-G.R. SP No. 05614-MIN and committed willful and deliberate forum shopping. SRMI's counsel, the Law Firm of Atty. Francis U. Ku and Associates, appears to be equally guilty of forum shopping, as the firm represented SRMI in G.R. No. 226574 as well as in the instant Petition and the preceding execution proceedings before the labor tribunals. Rule 7, Section 5 of the Rules of Court provides that if the acts of the party or his counsel clearly constitute willful and deliberate forum shopping, the same shall be ground for summary dismissal with prejudice and shall constitute direct contempt, as well as a cause for administrative sanctions. Consequently, SRMI and its counsel must be directed to show cause why they should not be cited in direct contempt for willful and deliberate forum shopping.
Doctrines
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Immutability of Judgments — Once a judgment has become final, it becomes immutable and unalterable; it cannot be changed in any way, even if the modification is for the correction of a perceived error, by the court which promulgated it or by a higher court. Judgments and orders should be final at some definite time based on law, as there would be no end to litigation. The winning party has an attendant right to enjoy the finality of the decision through the execution process. In this case, the Court held that the final and executory Resolution in G.R. No. 226574, which denied SRMI's petition and stated that no relief could be granted in relation to the compromise agreements, barred SRMI from relitigating the same agreements in the execution proceedings and before the CA.
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Grave Abuse of Discretion in Labor Cases — Grave abuse of discretion exists when the NLRC's findings and conclusions are not grounded on substantial evidence, which is such amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. In labor cases, judicial review under Rule 65 is confined to issues of want or excess of jurisdiction and grave abuse of discretion; the CA is not to decide whether the NLRC's decision on the merits was correct. If the NLRC's ruling has basis in the evidence and the applicable law and jurisprudence, no grave abuse of discretion exists. The Court applied this doctrine in holding that the CA erred in reversing the NLRC, because the NLRC's treatment of the amounts as advance or partial payments was supported by substantial evidence, particularly the ELA's findings.
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Respect for Factual Findings of Labor Tribunals — Factual findings of labor officials exercising quasi-judicial functions are accorded great respect and even finality by the courts when supported by substantial evidence. Questions of fact are for the labor tribunals to resolve and are binding upon the Supreme Court unless there is a showing of grave abuse of discretion or that they were arrived at arbitrarily or in utter disregard of the evidence on record. The Court held that the CA erred in reversing the NLRC's factual findings based solely on the text of the Compromise Agreements and a mere presumption, ignoring the ELA's categorical statement that the amounts were advance or partial payments.
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Requisites for a Valid Quitclaim — The Court has given effect to quitclaims in certain cases if the employer is able to prove the following requisites: (1) the employee executes a deed of quitclaim voluntarily; (2) there is no fraud or deceit on the part of any of the parties; (3) the consideration of the quitclaim is credible and reasonable; and (4) the contract is not contrary to law, public order, public policy, morals or good customs, or prejudicial to a third person with a right recognized by law. In this case, the NLRC found the monetary considerations unreasonable—Rama received PHP 50,000 against a judgment award of PHP 412,533.01 (12.12%), and Rodriguez received PHP 70,000 against a judgment award of PHP 383,678.20 (18.24%)—and declared the Compromise Agreements invalid. The Court upheld the NLRC's factual findings and ruled that the CA erred in reversing them.
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Forum Shopping — There is forum shopping when the following elements are present: (a) identity of parties, or at least such parties as representing the same interests in both actions; (b) identity of rights asserted and reliefs prayed for, the relief being founded on the same facts; and (c) the identity of the two preceding particulars, such that any judgment rendered in the other action will, regardless of which party is successful, amount to res judicata in the action under consideration. The test is whether the elements of litis pendentia are present, or whether a final judgment in one case amounts to res judicata in another. What is truly important is the vexation caused the courts and the parties by a party who asks different courts to rule on the same or related causes and/or to grant the same or substantially the same reliefs, creating the possibility of conflicting decisions. The Court held that SRMI committed willful and deliberate forum shopping by pursuing simultaneous remedies before the Supreme Court in G.R. No. 226574 and before the CA in CA-G.R. SP No. 08711-MIN, asserting the same Compromise Agreements and failing to disclose the pendency of the Supreme Court case.
Key Excerpts
- "There is forum shopping when the following elements are present: (a) identity of parties, or at least such parties as representing the same interests in both actions; (b) identity of rights asserted and reliefs prayed for, the relief being founded on the same facts; and (c) the identity of the two preceding particulars, such that any judgment rendered in the other action will, regardless of which party is successful, amount to res judicata in the action under consideration." — This passage states the canonical three-element test for forum shopping applied by the Court in finding SRMI guilty of willful and deliberate forum shopping.
- "It is almost trite to say that execution is the fruit and the end of the suit and is the life of the law. A judgment, if left unexecuted, would be nothing but an empty victory for the prevailing party. Litigation must end sometime and somewhere." — This passage, quoted from Heirs of Pidacan vs. Air Transportation Office, articulates the rationale for the immutability of judgments and the execution of final awards, which the Court used to condemn SRMI's dilatory tactics.
- "The CA's conclusion is surprising, considering ELA Dayot's categorical statement that Rodriguez and Rama were informed that the amounts they received under the Quitclaim and Compromise Agreements were merely partial payments. In the face of this unequivocal statement—which the CA chose to ignore—the CA's 'presumption' that ELA Dayot 'ensured that Rodriguez and Rama fully understood the terms and conditions embodied in the Compromise Agreements' has no basis." — This passage is the ratio decidendi on the grave abuse of discretion issue: the CA improperly substituted its own judgment for the NLRC's factual findings and relied on a presumption contradicted by the ELA's categorical statement.
- "By repeatedly attempting to evade payment of Rodriguez and Rama's claims and refusing to accept the Court's denial of its petition for review on certiorari in G.R. No. 226574, SRMI has, for years, deprived petitioners of their right to enjoy the finality of the CA's 2015 Decision and the monetary awards computed by the ELA in his June 30, 2017 Order." — This passage explains why the Court reversed the CA and remanded for recomputation with legal interest, emphasizing the prejudice caused by SRMI's repeated attempts to evade execution.
Precedents Cited
- SR Metals, Inc. vs. Adiong, G.R. No. 226574, June 3, 2019 [Unsigned Resolution, First Division] — The prior final and executory resolution denying SRMI's petition for review on certiorari; the Court held that no relief could be granted to SRMI in relation to the compromise agreements, and this ruling barred relitigation under the principle of immutability of judgments.
- Arcilla vs. San Sebastian College-Recoletos, Manila, G.R. No. 235863, October 10, 2022 [Per J. Leonen, Second Division] — Cited for the rule that the CA, in a Rule 65 petition, does not decide whether the NLRC's decision on the merits was correct; if the NLRC's ruling has basis in evidence and law, no grave abuse of discretion exists.
- Lanao Del Sur Electric Cooperative vs. LASURECO Employees Union-All Workers Alliance Trade Union, G.R. No. 206169, November 24, 2021 [Unsigned Resolution, Second Division] — A similar execution dispute where the Court rejected the employer's argument that the NLRC failed to consider alleged partial payments; the issue was a question of fact improper in a Rule 45 petition, and the NLRC's factual findings supported by substantial evidence were respected.
- Heirs of Pidacan vs. Air Transportation Office, 643 Phil. 657 (2010) [Per J. Nachura, Second Division] — Cited for the doctrine that execution is the fruit and end of the suit and the life of the law; courts must guard against schemes calculated to delay execution and deprive the winning party of the fruits of the verdict.
- Laya, Jr. vs. Philippine Veterans Bank, 823 Phil. 302 (2018) [Per J. Bersamin, En Banc] — Cited through the concurring opinion of J. Carpio for the principle that once a judgment becomes final, it becomes immutable and unalterable, and cannot be changed even to correct a perceived error by the court which promulgated it or by a higher court.
- Galicia vs. NLRC and Globe Paper Mills — Cited by the NLRC for the rule that a quitclaim consideration that is inordinately low and exceedingly unreasonable relative to the judgment award is palpably inequitable and does not bar the workers from pursuing their legitimate claims.
- Hubilla vs. HSY Marketing Ltd., Co., 823 Phil. 358 (2018) [Per J. Leonen, Third Division] — Cited for the rule that factual findings of labor officials exercising quasi-judicial functions are accorded great respect and even finality when supported by substantial evidence.
- Bergonio vs. DM Consunji, Inc., G.R. No. 254919, March 22, 2023 [Unsigned Resolution, First Division] — Cited for the rule that questions of fact are for the labor tribunals to resolve and are binding upon the Court unless there is a showing of grave abuse of discretion or that they were arrived at arbitrarily or in utter disregard of the evidence.
- Heirs of Inocentes Mampo and Raymundo Mampo vs. Morada, 888 Phil. 583 (2020) [Per J. Caguioa, First Division] — Cited for the elements of forum shopping and the test of litis pendentia or res judicata.
- De Lara vs. Atty. Carrasco, A.C. No. 13500, October 5, 2022 [Unsigned Resolution, First Division] — Cited for the rule that what is truly important in forum shopping is the vexation caused to the courts and the parties by a party who asks different courts to rule on the same or related causes and/or to grant the same or substantially the same reliefs.
- Boracay Island Water Co. vs. Malay Resorts Holdings, Inc., G.R. No. 235641, January 17, 2023 [Per J. Zalameda, First Division] — Cited for the justification of the prohibition against forum shopping: a party should not be allowed to pursue simultaneous remedies in two different courts, as this constitutes abuse of court processes.
- Westminster Seafarer Management Philippines, Inc. vs. Raz, G.R. No. 249344, April 5, 2022 [Unsigned Resolution, First Division] — Cited for the rule that when a judgment awarding a sum of money becomes final and executory, the rate of legal interest shall be 6% per annum from such finality until satisfaction, the interim period being deemed equivalent to a forbearance of credit.
- Lugawe vs. Pacific Cebu Resort International, Inc., G.R. No. 236161, January 25, 2023 [Per J. Hernando, First Division] — Cited for the definition of grave abuse of discretion in labor cases as existing when the NLRC's findings and conclusions are not grounded on substantial evidence.
Provisions
- Rule 45, Section 2, in relation to Rule 56, Section 5(a), Rules of Court — The Supreme Court denied SRMI's petition for review on certiorari in G.R. No. 226574 because it was filed beyond the 15-day reglementary period. This denial became final and executory and was the basis for the immutability of judgment ruling.
- Rule 65, Rules of Court — Judicial review of NLRC decisions under Rule 65 is confined to issues of want or excess of jurisdiction and grave abuse of discretion; it does not include an inquiry into the correctness of the evaluation of evidence. The Court applied this rule in holding that the CA erred in substituting its judgment for the NLRC's factual findings.
- Rule 7, Section 5, Rules of Court — If the acts of a party or counsel clearly constitute willful and deliberate forum shopping, the same shall be a ground for summary dismissal with prejudice and shall constitute direct contempt, as well as a cause for administrative sanctions. The Court applied this provision in directing SRMI and its counsel to show cause why they should not be held in direct contempt.
- Republic Act No. 9504, BIR Revenue Regulation No. 10-2008 dated July 8, 2008, and NLRC Memorandum Circular No. 90-02, Series of 2013 (September 18, 2013) — Cited in the ELA's June 30, 2017 Order for the rule that minimum wage earners' monetary awards are not subject to 5% withholding tax.
Notable Concurring Opinions
Gesmundo, C.J. (Chairperson), Hernando, Zalameda, and Rosario, JJ., concur.