DOCTRINE OF NON-INTERFERENCE OR DOCTRINE OF

JUDICIAL STABILITY

This doctrine in the regular orders or judgments of a co-equal court is an

elementary principle in the administration of justice: no court can interfere by
injunction with the judgments or orders of another court of concurrent jurisdiction
having the power to grant the relief sought by the injunction. The rationale for the
rule is founded on the concept of jurisdiction: a court that acquires jurisdiction over
the case and renders judgment, to the exclusion of all other coordinate courts, for
its execution and over all its incidents, and to control, in furtherance of justice, the
conduct of ministerial officers acting in connection with this judgment. (Atty.
Cabili vs. Judge Balindong; A.M. No. RTJ-10-2225, September 6, 2011)

DOCTRINE OF JUDICIAL STABILITY: Should one branch be permitted to

equally assert, assume, or retain jurisdiction over a case in controversy over which
another coordinate or co-equal branch has already assumed jurisdiction, then that
would be sanctioning undue interference by one branch over another. With that,
judicial stability would be meaningless precept in a well-ordered administration of
justice[Parcon vs. CA, 111 SCRA 262].

Law of Case Doctrine

Under the law of the case doctrine, a court is ordinarily precluded from
reexamining an issue previously decided by the same court, or a higher court in the
same case.[i]
The law of the case doctrine, when applied to the court that made the initial ruling
in question or a coordinate court, is a discretionary tool available to a court in order
to promote judicial efficiency.[ii]
The law of the case doctrine is a term applied in several distinct circumstances.
The purpose of this doctrine is twofold:[iii]
• to prevent the continued litigation of settled issues; and
• to assure compliance by inferior courts with the decisions of superior courts.
The doctrine of the law of the case points that when a court decides upon a rule of
law, that decision should continue to govern the same issues in subsequent stages
in the same case.[iv] This rule of practice promotes the finality and efficiency of
the judicial process by protecting against the agitation of settled issues.
When the question is a court’s revisitation of an issue previously decided by the
same court, the doctrine merely expresses the practice of courts generally to refuse
to reopen what has been decided, not a limit to their power.[v] The law of the case
doctrine applies with equal vitality in the context where a party has failed to appeal
the initial decision of a district court with respect to a particular issue.

WHAT IS THE "GLOBE" DOCTRINE?

In the case of Democratic Labor Association vs. Cebu Stevedoring Co., G.R. No.
L-10321, February 28, 1958, we stated that because of the modern complexity of
the relation between both employer and union structure, it becomes difficult to
determine from the evidence alone which of the several claimant groups forms a
proper bargaining unit; that it becomes necessary to give consideration to the
express will or desire of the employees — a practice designated as the "Globe
doctrine," which sanctions the holding of a series of elections, not for the purpose
of allowing the group receiving an over all majority of votes to represent all
employees, but for the specific purpose of permitting the employees in each of the
several categories to select the group which each chooses as a bargaining unit; that
the factors which may be considered and weighed in fixing appropriate units are:
the history, of their collective bargaining; the history, extent and type of
organization of employees in other plants of the same employer, or other
employers in the same industry; the skill, wages, work and working conditions of
the employees; the desires of the employees; the eligibility of the employees for
membership in the union or unions involved; and the relationship between the unit
or units proposed and the employer's organization, management and operation, and
the test in determining the appropriate bargaining unit is that a unit must effect a
grouping of employees who have substantial, mutual interests in wages, hours,
working conditions and other subjects of collective bargaining.
It is manifest, therefore, that "the desires of the employees" is one of the factors in
determining the appropriate bargaining unit. The respondent Court was simply
interested "in the verification of the evidence already placed on record and
submitted wherein the workers have signed manifestations and resolutions of their
desire to be separated from Kapisanan." Certainly, no one would deny the
respondent court's right of full investigation in arriving at a correct and conclusive
finding of fact in order to deny or grant the conclusive findings of fact in order to
deny or grant the petitions for certification election. On the contrary, all respondent
court, or any court for that matter, to investigate before acting, to do justice to the
parties concerned. And one way of determining the will or desire of the employees
is what the respondent court had suggested: a plebiscite — carried by secret ballot.
A plebiscite not to be conducted by the Department of Labor, as contemplated in a
certification election under Sec. 12 of the Magna Charter of Labor, R.A. No. 875,
but by the respondent court itself. As well as observed by the respondent court,
"the votes of workers one way or the other, in these cases will not by any chance
choose the agent or unit which will represent them anew, for precisely that is a
matter that is within the issues raised in these petitions for certification".
The test in determining whether an order or judgment is interlocutory or final is
"Does it leave something to be done in the trial court with respect to the merits of
the case? If it does, it is interlocutory; if it does not, it is final" (Moran's Comments
on the Rules of Court, 1952 Ed., Vol. I, p. 41). Having in view the avowed purpose
of the orders in question, as heretofore exposed, one should not stretch his
imagination far to see that they are clearly interlocutory, as they leave something
more to be done in the trial court and do not decide one way or the other the
petitions of the respondent unions. We are, therefore, constrained to hold, as we do
hereby hold, that the present appeals or petitions for review by certiorari, are not
authorized by law and should be dismissed (Section 2, Rule 44, Rules of Court).
There is, moreover, nothing, under the facts obtaining in these cases and the law on
the subject, which would warrant this Court to declare the orders under
consideration, illegal. (Kapisanan ng mga Manggagawa sa Manila Road Co. v.
Yard Crew Union; G.R. Nos. L16292-94)

Highly skilled or specialized technical workers may choose to form their own
bargaining unit because they may be in better position to bargain with the
employer considering the market value of their skills.
LIBERAL CONSTRUCTION PRINCIPLE:

The cases should be determined on the merits in order to give the parties full
opportunity to ventilate their causes and defenses, rather than on technicalities or
procedural imperfections. In that way, the ends of justice would be served better.
Rules of procedure are mere tools designed to expedite the decision or resolution
of cases and other matters pending in court. A strict and rigid application of rules,
resulting in technicalities that tend to frustrate rather than promote substantial
justice, must be avoided. In fact, Section 6 of Rule 1 states that the Rules shall
be liberally construed in order to promote their objective of ensuring the just,
speedy and inexpensive disposition of every action and
proceeding (DEVELOPMENT BANK OF THE PHILIPPINES vs. FAMILY
FOODS MANUFACTURING CO. LTD. G.R. No. 180458, July 30, 2009, Third
Division, Nachura, J.).
Corollary to this, it is settled that liberal construction of the rules may be
invoked in situations where there may be some excusable formal deficiency or
error in a pleading, provided that the same does not subvert the essence of the
proceeding and connotes at least a reasonable attempt at compliance with the
rules. After all, rules of procedure are not to be applied in a very rigid, technical
sense; they are used only to help secure substantial justice (MEDISERV, INC. vs.
COURT OF APPEALS, G.R. No. 161368, April 5, 2010, First Division, Villarama,
Jr., J.)
Thus, in Republic vs. Jennifer Cagandahan, G.R. No. 166676,
September 12, 2008, 2nd Division, the Supreme Court agreed that there is
substantial compliance with Rule 108 (which requires the civil registrar and all
persons who have or claim any interest which would be affected by the Petition
shall be made parties to the proceedings) when respondent furnished a copy of the
petition to the local civil registrar. The High Court invoked Section 6, Rule 1 of
the Rules of Court which states that courts shall construe the Rules liberally to
promote their objectives of securing to the parties a just, speedy and inexpensive
disposition of the matters brought before it.