If the NLRC has rendered a judgment on the issue of employer-employee relationship and such judgment has become final, should the Court of Appeals in a separate case merely yield to the NLRC’s findings owing to the doctrine of res judicata or immutability of final judgments?

The Supreme Court, in MSI-ELU-OLALIA, et al. vs. Manila Cordage Company (MCC) and Manco Synthetics, Ins. (MSI), G.R. No. 260801, 13 May 2024, a case originating from the DOLE’s exercise of its visitorial and enforcement powers, held that the Court of Appeals is not bound by the judgment of the NLRC in a separate case even if it attained finality if it will be tantamount to a denial of due process.

One of the primary considerations in resolving labor cases is the right to due process. This cannot be defeated by a technical rule of procedure such as the doctrine of res judicata or immutability of final judgments. The NLRC in a prior complaint for illegal strike filed by the company against the workers dismissed the complaint for lack of employer-employee relationship between the parties. This NLRC ruling became final as no appeal was filed. The Supreme Court ruled that the Court of Appeals is not bound by the NLRC’s finding of no employer-employee relationship in the said illegal strike case even if it attained finality because it will be tantamount to a denial of due process. The Court recognized the predicament of the workers to not appeal the NLRC ruling as the complaint for illegal strike was dismissed anyway. Under the circumstances, the Court declared that the Court of Appeals cannot be bound by the NLRC ruling and instead has the authority to make its own finding on the issue of employer-employee relationship.

Download: https://sc.judiciary.gov.ph/260801-manco-synthetic-inc-employee-labor-union-organized-labor-union-in-line-industries-and-agriculture-msi-elu-olalia-and-manila-cordage-company-employees-labor-union-organized-labor-union-in-line-i/