#22 Ruben Delfin, et al. vs. Hon. Amado G.

Inciong, in which rendered the decision had jurisdiction over the

his capacity as Deputy Minister of Labor, et al. subject matter and over the parties. Third, the judgment
rendered therein was a judgment on the merits of the
G.R. No. 50661. December 10, 1990
case after the parties presented their evidence, oral and
Facts: documentary Fourth, private respondents NLRC and
then Deputy Minister Inciong did not commit any grave
The 136 petitioners herein are former employees of abuse of discretion amounting to lack of jurisdiction
private respondent Atlantic Container Corporation when they ruled that there is, between the first and the
(Atlantic). Petitioners organized themselves into the second complaints, identity of causes of action, subject
Atlantic Container Employees Organization and matter and parties. Bringing the same action in the
affiliated with the Federation of Democratic Labor name of the individual members of the union will NOT
Unions (FEDLU). Petitioners filed a complaint against take the case out of the ambit of the principle of Res
their employer for not executing the contents of their judicata.
collective bargaining agreement. However, upon trial, it
was discovered that the petitioners were the ones who
did not follow the agreement as they continually held
strikes and asked for an increase in salary. The Court of
Industrial Relations (CIR) was abolished during the
pendency of the case and it was passed to the NLRC.
The National Labor Relations Commission (NLRC) ruled
that 86 out of the 136bpetitioners be reinstated in the
position. The petitioners appealed which was
subsequently denied. The petitioners then filed the
same complaint to the Minister of Labor, Amado
Inciong, who dismissed the complaint on the following
grounds: 1) that the charge subject of the petition is
barred by res judicata; 2) that petitioners’ cause of
action had prescribed and that the same is now barred
by laches; 3) that the corporate and distinct personality
of respondent Inland was not successfully pierced.

Issue:

Whether or not the case is barred by res judicata.

Held:

Yes. For a prior judgment to constitute a bar to a

subsequent case, the following requisites must concur:
a) it must be a final judgment or order; (b) the court
rendering the same must have jurisdiction over the
subject matter and over the parties; (c) it must be a
judgment or order on the merits, and (d) there must be
between the two cases identity of parties, subject
matter and cause of action. There is no question that
the first three (3) requisites are present in this case.
First, the decision in the first complaint had already
become final and executory. The motion for
reconsideration filed by the union in that case was
denied and no petition was filed subsequent the denial.
Thus it became final and executory. Second, the CIR