Sara Lee Ph vs Mataklaw
GR No. 180147, January 14, 2015
FACTS:
Aris Philippines permanently ceased operations on October 9, 1995
displacing 5,984 rankand-file employees.
On October 26, 1995, Fashion Accessories Philippines (FAPI) was
incorporated prompting former Aris employees to file a case for
illegal dismissal on the allegations that FAPI was a continuing
business of Aris. Sare Lee Corporation, Sara Lee Philippines and
Cesar Cruz were impleaded as defendants being major stockholders
of FAPI and officers of Aris, respectively.
On 30 October 2004, the Labor Arbiter found the dismissal of 5,984
Aris employees illegal and awarded them monetary benefits
amounting to P3.4 Billion. The judgment award is composed of
separation pay of one month for every year of service, backwages,
moral and exemplary damages and attorneyʼs fees.
The Corporations filed a Notice of Appeal with Motion to Reduce
Appeal Bond. They posted a P4.5 Million bond. The NLRC granted
the reduction of the appeal bond and ordered the Corporations to
post an additional P4.5 Million bond.
The 5,984 former Aris employees, represented by Emilinda
Macatlang (Macatlang petition), filed a petition for review before
the Court of Appeals insisting that the appeal was not perfected due
to failure of the Corporations to post the correct amount of the
bond which is equivalent to the judgment award.
While the case was pending before the appellate court, the NLRC
prematurely issued an order setting aside the decision of the Labor
Arbiter for being procedurally infirmed.
The Court of Appeals, on March 26, 2007, ordered the Corporations
to post an additional appeal bond of P1 Billion.
ISSUE: W/n the NLRC violated Judicial Courtesy by prematurely
issuing an order while the case was pending in the CA
HELD:
YES. The Corporations argue that there was no legal impediment for
the NRLC to issue its 19 December 2006 Resolution vacating the
Labor Arbiterʼs Decision as no TRO or injunction was issued by the
Court of Appeals. The Corporations assert that the rule on judicial
courtesy remains the exception rather than the rule. THE SUPREME
COURT DOES NOT AGREE WITH THIS CONTENTION.
The Corporationsʼ argument is specious. Judicial courtesy indeed
applies if there is a strong probability that the issues before the
higher court would be rendered moot as a result of the continuation
of the proceedings in the lower court. This is the exception
contemplated in the aforesaid ruling and it obtains in this case. The
December 19, 2006 ruling of the NLRC would moot the appeal filed
before the higher courts because the issue involves the appeal bond
which is an indispensable requirement to the perfection of the
appeal before the NLRC. Unless this issue is resolved, the NLRC
should be precluded from ruling on the merits on the case. This is
the essence of judicial courtesy.
PGBI v COMELEC
GR No. 190529, April 29, 2010
FACTS:
For the upcoming May 2010 elections, the COMELEC en banc issued
on October 13, 2009 Resolution No. 8679 deleting several party-list
groups or organizations from the list of registered national, regional
or sectorial parties, organizations or coalitions.
Among the party-list organizations affected was PGBI; it was
delisted because it failed to get 2% of the votes cast in 2004 and it
did not participate in the 2007 elections. Nevertheless, the
COMELEC stated in this Resolution that any national, regional
sectoral party or organizations or coalitions adversely affected can
personally or through its authorized representative file a verified
opposition on October 26, 2009.
PGBI filed its Opposition to Resolution No. 8679, but likewise
sought, through its pleading, the admission ad cautelam of its
petition for accreditation as a party-list organization under the
Party-List System Act. One of PCGIʼs arguments was that the
Supreme Courtʼs ruling in G.R. No. 177548 – Philippine Mines Safety
Environment Association, also known as "MINERO" v. Commission
on Elections – cannot apply in the instant controversy for two
reasons: (a) the factual milieu of the cited case is removed from
PGBIʼs; (b) MINERO, prior to delisting, was afforded the opportunity
to be heard, while PGBI and the 25 others similarly affected by
Resolution No. 8679 were not. Additionally, the requirement of
Section 6(8) has been relaxed by the Courtʼs ruling in G.R. No.
179271 (Banat v. COMELEC) and the exclusion of PGBI and the 25
other party-list is a denial of the equal protection of the laws
ISSUE: w/n the MINERO case can be used as precedent in the case-
at-bar
HELD:
NO. Our Minero ruling is an erroneous application of Section 6(8) of
RA 7941; hence, it cannot sustain PGBIʼs delisting from the roster of
registered national, regional or sectorial parties, organizations or
coalitions under the party-list system.
We initially dismissed the petition in light of our ruling in "MINERO"
v. Commission on Elections (Minero); we said that no grave abuse of
discretion exists in a ruling that correctly applies the prevailing law
and jurisprudence. Applying Section 6(8) of RA 7941, the Court
disqualified MINERO under the following reasoning: Since petitioner
by its own admission failed to get 2% of the votes in 2001 and did
not participate at all in the 2004 elections, it necessarily failed to get
at least two per centum (2%) of the votes cast in the two preceding
elections. COMELEC, therefore, is not duty bound to certify it.
PGBI thus asserts that Section 6(8) does not apply to its situation, as
it is obvious that it failed to participate in one but not in the two
preceding elections. Implied in this is that it also failed to secure the
required percentage in one but not in the two preceding elections.
First, the law is clear – the COMELEC may motu proprio or upon
verified complaint of any interested party, remove or cancel, after
due notice and hearing, the registration of any national, regional or
sectoral party, organization or coalition if it: (a) fails to participate in
the last two preceding elections; or (b) fails to obtain at least two
per centum (2%) of the votes cast under the party-list system in the
two preceding elections for the constituency in which it has
registered. The word "or" is a disjunctive term signifying
disassociation and independence of one thing from the other things
enumerated; it should, as a rule, be construed in the sense in which
it ordinarily implies, as a disjunctive word.
Thus, the plain, clear and unmistakable language of the law provides
for two (2) separate reasons for delisting.
Minero is diametrically opposed to the legislative intent of Section
6(8) of RA 7941, as PGBIʼs cited congressional deliberations clearly
show. Minero therefore simply cannot stand. Its basic defect lies in
its characterization of the non-participation of a party-list
organization in an election as similar to a failure to garner the 2%
threshold party-list vote. What Minero effectively holds is that a
party list organization that does not participate in an election
necessarily gets, by default, less than 2% of the party-list votes. To
be sure, this is a confused interpretation of the law, given the lawʼs
clear and categorical language and the legislative intent to treat the
two scenarios differently. A delisting based on a mixture or fusion of
these two different and separate grounds for delisting is therefore a
strained application of the law – in jurisdictional terms, it is an
interpretation not within the contemplation of the framers of the
law and hence is a gravely abusive interpretation of the law.
The doctrine of stare decisis enjoins adherence to judicial
precedents. It requires courts in a country to follow the rule
established in a decision of its Supreme Court. That decision
becomes a judicial precedent to be followed in subsequent cases by
all courts in the land. The doctrine of stare decisis is based on the
principle that once a question of law has been examined and
decided, it should be deemed settled and closed to further
argument.
Stare decisis simply means that for the sake of certainty, a
conclusion reached in one case should be applied to those that
follow if the facts are substantially the same, even though the
parties may be different. It proceeds from the first principle of
justice that, absent any powerful countervailing considerations, like
cases ought to be decided alike. Thus, where the same questions
relating to the same event have been put forward by the parties
similarly situated as in a previous case litigated and decided by a
competent court, the rule of stare decisis is a bar to any attempt to
relitigate the same issue.
The doctrine though is not cast in stone for upon a showing that
circumstances attendant in a particular case override the great
benefits derived by our judicial system from the doctrine of stare
decisis, the Court is justified in setting it aside.
As our discussion above shows, the most compelling reason to
abandon Minero exists; it was clearly an erroneous application of
the law – an application that the principle of stability or
predictability of decisions alone cannot sustain. Minero did
unnecessary violence to the language of the law, the intent of the
legislature, and to the rule of law in general.
Clearly, we cannot allow PGBI to be prejudiced by the continuing
validity of an erroneous ruling. Thus, we now abandon Minero and
strike it out from our ruling case law.
Lazatin vs Decierto
GR No. 147097, June 5, 2009
FACTS:
On July 22, 1998, the Fact-Finding and Intelligence Bureau of the
Office of the Ombudsman filed a Complaint-Affidavit docketed as
OMB-0-98-1500, charging herein petitioners with Illegal Use of
Public Funds as defined and penalized under Article 220 of the
Revised Penal Code and violation of Section 3, paragraphs (a) and
(e) of Republic Act (R.A.) No. 3019, as amended.
The complaint alleged that there were irregularities in the use by
then Congressman Carmello F. Lazatin of his Countrywide
Development Fund (CDF) for the calendar year 1996, i.e., he was
both proponent and implementer of the projects funded from his
CDF; he signed vouchers and supporting papers pertinent to the
disbursement as Disbursing Officer; and he received, as claimant, 18
checks amounting to ₱4,868,277.08. Thus, petitioner Lazatin, with
the help of petitioners Marino A. Morales, Angelito A. Pelayo and
Teodoro L. David, was allegedly able to convert his CDF into cash.
Fourteen counts each of Malversation of Public Funds and violation
of Section 3 (e) of R.A. No. 3019 were filed by the Evaluation and
Preliminary Investigation Bureau (EPIB) after the preliminary
investigation was conducted. This was approved by the
Ombudsman; hence, 28 informations docketed as Criminal Case
Nos. 26087 to 26114 were filed against the petitioners before the
Sandiganbayan.
Petitioner Lazatin and his co-petitioners then filed their respective
Motions for Reconsideration/Reinvestigation, which motions were
granted by the Sandiganbayan (Third Division). The Sandiganbayan
also ordered the prosecution to re-evaluate the cases against
petitioners.
The OSP recommended the dismissal of the cases against
petitioners for lack or insufficiency of evidence. The Ombudsman,
however, ordered the Office of the Legal Affairs (OLA) to review the
OSP Resolution. The OLA recommended that the OSP Resolution be
disapproved and the OSP be directed to proceed with the trial of
the cases against petitioners. The cases were then returned to the
Sandiganbayan for continuation of criminal proceedings.
Petitioners asseverate that the Ombudsman had no authority to
overturn the OSP's Resolution dismissing the cases against
petitioners because, under Section 13, Article XI of the 1987
Constitution, the Ombudsman is clothed only with the power to
watch, investigate and recommend the filing of proper cases against
erring officials, but it was not granted the power to prosecute. They
point out that under the Constitution, the power to prosecute
belongs to the OSP (formerly the Tanodbayan), which was intended
by the framers to be a separate and distinct entity from the Office
of the Ombudsman. Petitioners conclude that, as provided by the
Constitution, the OSP being a separate and distinct entity, the
Ombudsman should have no power and authority over the OSP.
Thus, petitioners maintain that R.A. No. 6770 (The Ombudsman Act
of 1989), which made the OSP an organic component of the Office
of the Ombudsman, should be struck down for being
unconstitutional.
ISSUE: W/n the SC can apply the Doctrine of Stare Decisis in the
case-at-bar where the lis mota of the case is its constitutionality
HELD: power of control and supervision over the OSP, to disapprove or
overturn any resolution issued by the latter.
Yes. Petitioners' attack against the constitutionality of R.A. No. 6770
is stale. It has long been settled that the provisions of R.A. No. 6770
granting the Office of the Ombudsman prosecutorial powers and
placing the OSP under said office have no constitutional infirmity.
The issue of whether said provisions of R.A. No. 6770 violated the
Constitution had been fully dissected as far back as 1995 in Acop v.
Office of the Ombudsman.

Petitioners now assert that the Court's ruling on the

constitutionality of the provisions of R.A. No. 6770 should be
revisited and the principle of stare decisis set aside. Again, this
contention deserves scant consideration.

The doctrine of stare decisis et non quieta movere (to adhere to

precedents and not to unsettle things which are established) is
embodied in Article 8 of the Civil Code of the Philippines. The
doctrine of stare decisis enjoins adherence to judicial precedents. It
requires courts in a country to follow the rule established in a
decision of the Supreme Court thereof. That decision becomes a
judicial precedent to be followed in subsequent cases by all courts
in the land. The doctrine of stare decisis is based on the principle
that once a question of law has been examined and decided, it
should be deemed settled and closed to further argument.

In this case, petitioners have not shown any strong, compelling

reason to convince the Court that the doctrine of stare
decisis should not be applied to this case. They have not successfully
demonstrated how or why it would be grave abuse of discretion for
the Ombudsman, who has been validly conferred by law with the
LIGHT RAIL TRANSIT AUTHORITY vs PILI
GR No. 202047, June 8, 2016
FACTS:
LRTA is a government-owned and controlled corporation created
under Executive Order (EO) No. 603 for the "construction,
operation, maintenance, and/or lease of light rail transit systems in
the Philippines." It entered into a ten-year operations and
management agreement with Meralco Transit Organization, Inc.
(MTOI) from June 8, 1984 to June 8, 1994.
MTOI, a corporation organized under the Corporation Code, hired
its own employees and thereafter entered into collective bargaining
agreements (CBAs) with the unions of its employees.
However, on April 7, 1989, the Commission on Audit declared the
Agreement between LRTA and MTOI void. As a result, on June 9,
1989, LRTA purchased all the shares of stock of MTOI and renamed
MTOI to Metro Transit Organization, Inc. (Metro) and formally
declared Metro as its wholly-owned subsidiary.
On July 25, 2000, the union of rank-and-file employees of Metro
staged a strike over a bargaining deadlock which resulted in the
paralysis in the operations of Metro. On July 31, 2000, the
Agreement expired when LRTA decided no longer to renew. On
September 30, 2000, Metro ceased its operations.
Respondents were employees of Metro who have been terminated
upon the expiration of the Agreement. While the rest of the
respondents filed cases involving purely monetary claims in the
form of separation pays, balances of separation pays, and other
unpaid claims, respondent Noel B. Pili, in addition to his monetary
claims, alleged that he was illegally dismissed.
On the other hand, the rest of the respondents filed cases for purely
monetary claims. They assert that under Article 4.05 of the
Agreement, LRTA contractually bound itself to shoulder and provide
all "Operating Expenses" of Metro.
The Labor Arbiter decided in favor of the respondents (Pili et al)
On December 5, 2005, LRTA appealed to the NLRC. NLRC found that
there was no illegal dismissal as Pili's dismissal was valid on account
of the termination of the Agreement between Metro and LRTA. The
NLRC issued a Resolution modifying in part the Decision of the Labor
Arbiter. It ordered METRO and LRTA to pay complainant-appellee
Pili the balance of his separation pay in the amount of P165,398.35
plus ten percent (10%) of the award as attorney's fees and affirming
the monetary awards in the appealed Decision in its entirety
including the 10% attorney's fees to complainants appellees Lirio, et
al.
Thereafter, LRTA filed a petition for certiorari under Rule 65 before
the CA. The CA set aside the Resolution of the NLRC and reinstated
the October 27, 2005 Decision of the Labor Arbiter in toto. The CA
found that Pili was illegally dismissed as the expiration of the
Agreement between LRTA and Metro was not a valid ground to
terminate Pili's employment.
The CA denied the Motion for Reconsideration.
ISSUE: W/n the doctrine of Stare Decisis is applicable in this case
HELD:
YES. We find that the application of the doctrine of stare decisis is in
order.
The doctrine of stare decisis et non quieta movere means "to
adhere to precedents, and not to unsettle things which are
established." Under this doctrine, when this Court has once laid
down a principle of law as applicable to a certain state of facts, it
will adhere to that principle, and apply it to all future cases, where
facts are substantially the same; regardless of whether the parties
and property are the same.
The basic facts in this petition are the same as those in the case of
LRTA v. Mendoza. Thus, we find that LRTA is solidarity liable for the
monetary claims of respondents, in light of this Court's findings in
said case. It is the duty of the Court to apply the previous ruling in
LRTA v. Mendoza in accordance with the doctrine of stare decisis.
Once a case has been decided one way, any other case involving
exactly the same point at issue, as in the present case, should be
decided in the same manner.
QUINTANAR v COCA COLA
GR No. 210565, June 28, 2016
FACTS:
Complainants allege that they are former employees directly hired
by respondent Coca-Cola on different dates from 1984 up to 2000,
assigned as regular Route Helpers under the direct supervision of
the Route Sales Supervisors.
Complainants allege that the Department of Labor and Employment
(DOLE) conducted an inspection of Coca-Cola to determine whether
it is complying with the various mandated labor standards, and
relative thereto, they were declared to be regular employees of
Coca-Cola, which was held liable to pay complainants the
underpayment of their 13th month pay, emergency cost of living
allowance (ECOLA), and other claims.
As soon as respondents learned of the filing of the claims with
DOLE, they were dismissed on various dates in January 2004. Their
claims were later settled by the respondent company, but the
settlement allegedly did not include the issues on reinstatement
and payment of CBA benefits. Thus, on November 10, 2006, they
filed their complaint for illegal dismissal.
In support of their argument that they were regular employees of
Coca-Cola, the complainants relied on the pronouncement of the
Supreme Court in the case of CCBPI vs. NOWM wherein it stated
that Interserve was a labor-only contractor.
The labor arbiter rendered its decision granting the prayer in the
complaint. It ordered Coca-Cola to reinstate the petitioners to their
former positions and to pay their full backwages. Similar to the
conclusion reached by the LA, the NLRC found that the petitioners
were regular employees of Coca-Cola. In its decision, it found that
the relationship between the parties in the controversy bore a
striking similarity with the facts in the cases of Coca-Cola Bottlers
Philippines, Inc. v. National Organization of Workingmen10(N.O.W.)
and Magsalin v. National Organization of Workingmen (Magsalin).
The NLRC, thus, echoed the rulings of the Court in the said cases
which found the employees involved, like the petitioners in this
case, as regular employees of CocaCola.
The CA, however, reversed the decisions of the LA and the NLRC.
They said that Interserve was a legitimate job contractor, not a
labor-only contractor. The petitioners sought reconsideration, but
they were rebuffed. Hence, this petition.
ISSUE: w/n the Doctrine of Stare Decisis can be applied in this case
HELD:
YES. In Pacquing v. Coca-Cola Philippines, Inc. (Pacquing),33 the
Court applied the ruling in Magsalin under the principle of stare
decisis et non quieta movere (follow past precedents and do not
disturb what has been settled). It was stressed therein that because
the petitioners, as route helpers, were performing the same
functions as the employees in Magsalin, which were necessary and
desirable in the usual business or trade of Coca- Cola Philippines,
Inc., they were considered regular employees of Coca-Cola entitled
to security of tenure.
The Court determined the existence of an employer-employee
relationship between the parties therein considering that the
contract of service between Coca-Cola and Interserve showed that
the former indeed exercised the power of control over the
complainants therein.
The Court once more asserted the findings that route-helpers were
indeed employees of Coca-Cola in Coca-Cola Bottlers Philippines,
Inc. v. Dela Cruz and, recently, in Basan v. Coca-Cola Bottlers
Philippines, Inc. and that the complainants therein were illegally
dismissed for want of just or authorized cause. Similar dispositions
by the CA were also upheld by this Court in N.O.W43 and Ostani,
through minute resolutions.
It bears mentioning that the arguments raised by Coca-Cola in the
case at bench even bear a striking similarity with the arguments it
raised before the CA in N.O.W and Ostani.
From all these, a pattern emerges by which Coca-Cola consistently
resorts to various methods in order to deny its route-helpers the
benefits of regular employment. Despite this, the Court, consistent
with sound pronouncements above, adopts the rulings made in
Pacquing that Interserve was a labor-only contractor and that Coca-
Cola should be held liable pursuant to the principle of stare decisis
et non quieta movere.
Coca-Cola has not shown any strong and compelling reason to
convince the Court that the doctrine of stare decisis should not be
applied. It failed to successfully demonstrate how or why both the
LA and the NLRC committed grave abuse of discretion in sustaining
the pleas of the petitioners that they were its regular employees
and not of Interserve.
UCPB vs UY
GR No. 204039, January 10, 2018
FACTS:
Prime Town Property Group, Inc. (PPGI) and E. Ganzon Inc. were the
joint developers of the Kiener Hills Mactan Condominium Project
(Kiener Hills). In 1997, spouses Walter and Lily Uy (respondents)
entered into a Contract to Sell with PPGI for a unit in Kiener Hills.
On April 23, 1998, PPGI and petitioner United Coconut Planters
Bank (UCPB) executed the following: Memorandum of Agreement
(MOA), and Sale of Receivables and Assignment of Rights and
Interests. By virtue of the said agreements, PPGI transferred the
right to collect the receivables of the buyers, which included
respondents, of units in Kiener Hills. The parties entered into the
said agreement as PPGI's partial settlement of its ₱1,
814,500,000.00 loan with UCPB.
On 17 April 2006, the Housing and Land Use Regulatory Board
Regional Office (HLURB Regional Office) received respondents'
complaint for sum of money and damages against PPGI and UCPB.
They claimed that in spite of their full payment of the purchase
price, PPGI failed to complete the construction of their units in
Kiener Hills.Tthe HLURB Regional Office found that respondents
were entitled to a refund in view of PPGI' s failure to complete the
construction of their units. Nonetheless, it found that UCPB cannot
be solidarily liable with PPGI because only the accounts receivables
were conveyed to UCPB and not the entire condominium project.
Unsatisfied, respondents appealed before the HLURB Board of
Commissioners (HLURB Board). It was GRANTED.
Aggrieved, UCPB appealed before the OP. The decision of HLURB
was AFFIRMED by the OP.
Undeterred, UCPB appealed before the CA. The CA affirmed with
modification the OP decision.
In addition, the appellate court noted the pronouncements of the
CA in United Coconut Planters Bank v. O'Halloran (O'Halloran). It
explained that it involved similar facts and issues where the CA
ruled that the assignment of the receivables did not make UCPB the
developer of Kiener Hills it being merely the assignee of the
receivables under the contract to sell and, as such, UCPB cannot be
deemed as the debtor with respect to the construction,
development, and delivery of the subject condominium units.
ISSUE: W/n the CA erred when it misconstrued the applicability of
UCPB v OʼHalloran to the case-at-bar
HELD:
YES, the CA erred. It must be remembered that when a case is
appealed, the appellate court has the power to review the case in
its entirety. Thus, when UCPB appealed the present controversy
before the Court, it was not merely limited to determine whether
the CA accurately set UCPB's liability against respondents. It is also
empowered to determine whether the appellate court's
determination of liability was correct in the first place.
This is especially true considering that the issue of the nature of
UCPB's liability is closely intertwined and inseparable from the
determination of the amount of its actual liability.
However, Stare Decisis applies only to cases decided by the
Supreme Court. As above-mentioned, respondents bewail the
reliance of the CA on 0 'Halloran arguing that it was not a binding
precedent since it was not issued by this Court. In other words, the
doctrine of stare decisis becomes operative only when judicial –
precedents are set by pronouncements of this Court to the
exclusion of lower courts.

It is true regardless whether the decisions of the lower courts are

logically or legally sound as only decisions issued by this Court
become part of the legal system. At the most, decisions of lower
courts only have a persuasive effect. Thus, respondents are correct
in contesting the application of the doctrine of stare decisis when
the CA relied on decisions it had issued.