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PCSO Unfair Labor Practice Case

The document discusses a case regarding whether filing a petition for damages before the Court of Industrial Relations (CIR) constituted splitting a cause of action. The CIR ruled in favor of the petitioner regarding an unfair labor practice complaint. While the case was pending appeal, the petitioner filed a petition for damages with the CIR, citing a recent Supreme Court case establishing the CIR's jurisdiction over such claims. The Court of Appeals reversed damages award, finding it constituted splitting the cause of action. However, the Supreme Court ultimately ruled that the petition for damages did not constitute splitting the cause of action, as the CIR previously did not have jurisdiction over damages claims. Filing after the jurisdiction was established and before the initial ruling was final was therefore allowed.

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341 views1 page

PCSO Unfair Labor Practice Case

The document discusses a case regarding whether filing a petition for damages before the Court of Industrial Relations (CIR) constituted splitting a cause of action. The CIR ruled in favor of the petitioner regarding an unfair labor practice complaint. While the case was pending appeal, the petitioner filed a petition for damages with the CIR, citing a recent Supreme Court case establishing the CIR's jurisdiction over such claims. The Court of Appeals reversed damages award, finding it constituted splitting the cause of action. However, the Supreme Court ultimately ruled that the petition for damages did not constitute splitting the cause of action, as the CIR previously did not have jurisdiction over damages claims. Filing after the jurisdiction was established and before the initial ruling was final was therefore allowed.

Uploaded by

kamiruhyun
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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5 QUADRA vs.

CA

G.R. No. 147593 July 31, 2006

Facts:

Petitioner, the chief legal officer of the respondent Philippine Charity


Sweepstakes Office PCSO who was dismissed for violation of Civil Service Law
and for neglect of duty and conduct prejudicial to the interest of the service, filed
with the Court of Industrial Relations (CIR) a complaint for unfair labor practice.
The CIR ruled that respondent PCSO is guilty of unfair labor practice and ordered
the reinstatement of petitioner. Respondent PCSO complied with the decision of
the CIR but it filed with the Supreme Court a petition for review on certiorari
assailing the decision of the CIR.

During the pendency of the case in the Supreme Court, petitioner filed with the
CIR a "Petition for Damages" citing the case of Rheem of the Philippines, Inc. v.
Ferrer, where the SC upheld the jurisdiction of the CIR over claims for damages
incidental to an employee's dismissal. Respondent PCSO moved to dismiss the
petition for damages on the ground that the cause of action is barred by prior
judgment, it appearing that two complaints are brought for different parts of a
single cause of action. The Labor Arbiter rendered a decision awarding moral and
exemplary damages to petitioner. The NLRC affirmed the decision of the Labor
Arbiter, prompting respondent PCSO to file a petition for certiorari with the Court
of Appeals. The Court of Appeals reversed the decision of the NLRC stating that
the petition claiming moral and exemplary damages filed by petitioner after
respondent PCSO had complied with the CIR decision of reinstatement and
backwages amounted to splitting of cause of action. Petitioner filed a motion for
reconsideration of the decision of the Court of Appeals, but it was denied, thus it
file petition for review the decision of the CA.

Issue: Whether or not the filing of the petition for damages before the CIR
constitute splitting of cause of action.

Ruling:

No. The Revised Rules of Court prohibits parties from instituting more than
one suit for a single cause of action. Splitting a cause of action is the act of
dividing a single cause of action, claim or demand into two or more parts, and
bringing suit for one of such parts only, intending to reserve the rest for another
separate action. The purpose of the rule is to avoid harassment and vexation to
the defendant and avoid multiplicity of suits. The prevailing rule at the time that
the action for unfair labor practice and illegal dismissal was filed and tried before
the CIR was that said court had no jurisdiction over claims for damages. Hence,
petitioner, at that time, could not raise the issue of damages in the proceedings.
However, on January 27, 1967, the Supreme Court rendered its ruling in Rheem
of the Philippines, Inc., et al. v. Ferrer, et al. upholding the jurisdiction of the CIR
over claims for damages incidental to an employee's illegal dismissal. Petitioner
properly filed his claim for damages after the declaration by the Court and before
the ruling on their case became final. Such filing could not be considered as
splitting of cause of action.

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