The Supreme Court ruled that employees who initially filed a case for labor standards violations with the Department of Labor and Employment (DOLE) and subsequently filed an illegal dismissal case with the National Labor Relations Commission (NLRC) after being terminated, did not commit forum shopping. The Court emphasized that there was no identity of causes of action between the two cases, as the DOLE case involved violations of labor standards while the NLRC case questioned the legality of their dismissal. This decision clarifies the circumstances under which filing separate labor-related cases does not constitute an abuse of judicial remedies, safeguarding employees’ rights to seek redress for distinct labor violations.

Navigating Legal Waters: When is Filing Separate Labor Cases Not Forum Shopping?

The case revolves around Kapisanang Pangkaunlaran ng Kababaihang Potrero, Inc. (KPKPI), a non-profit organization, and its Program Manager, Milagros H. Reyes, who were sued by several employees for labor violations and illegal dismissal. The central legal question is whether the employees, by initially filing a complaint for underpayment and other labor standard benefits with the DOLE and later filing an illegal dismissal case with the NLRC, engaged in forum shopping. This issue is critical in determining whether the employees’ claims should be heard on their merits or dismissed for abusing the legal process.

Forum shopping, in legal terms, is the act of repetitively seeking judicial remedies in different courts, simultaneously or successively, based on the same facts and issues, with the goal of obtaining a favorable decision. The Supreme Court has defined forum shopping as:

“when one party repetitively avails of several judicial remedies in different courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in, or already resolved adversely, by some other court.”^[21]

The key consideration in determining whether forum shopping exists is the vexation caused to the courts and parties-litigants by a party seeking rulings on the same or related causes in different forums, potentially leading to conflicting decisions. This principle aims to prevent the abuse of judicial processes and ensure the efficient administration of justice.

In this case, the employees initially filed a complaint with the DOLE for underpayment of wages and non-payment of labor standard benefits. Subsequently, after being terminated from their employment, they filed a separate complaint with the NLRC for illegal dismissal. The NLRC and the Court of Appeals (CA) initially found the employees guilty of forum shopping. However, the Supreme Court reversed this finding, holding that the employees’ actions did not constitute forum shopping because the two cases involved distinct causes of action.

The Court emphasized that the DOLE case pertained to violations of labor standard provisions, which fall under the jurisdiction of the DOLE, while the NLRC case concerned the legality of the employees’ dismissal, which falls under the jurisdiction of the NLRC. The Labor Code provides for these two separate remedies for distinct causes of action. Specifically:

• The DOLE’s jurisdiction covers violations of labor standard laws where an employer-employee relationship exists.
• The NLRC’s jurisdiction covers cases of illegal dismissal.

The Supreme Court noted that at the time the DOLE case was initiated, the employees’ only cause of action was the employer’s violation of labor standard laws. It was only after the filing of the DOLE case that the employees were terminated, leading to the filing of the illegal dismissal case with the NLRC. Under these circumstances, the employees had no choice but to avail themselves of different forums to seek redress for their grievances.

Furthermore, the employees had withdrawn the DOLE case after instituting the NLRC case, demonstrating their intent not to pursue overlapping remedies. The Supreme Court cited its pronouncement in Consolidated Broadcasting System v. Oberio:

“Under Article 217 of the Labor Code, termination cases fall under the jurisdiction of Labor Arbiters. Whereas, Article 128 of the same Code vests the Secretary of Labor or his duly authorized representatives with the power to inspect the employer’s records to determine and compel compliance with labor standard laws. The exercise of the said power by the Secretary or his duly authorized representatives is exclusive to cases where [the] employer-employee relationship still exits. Thus, in cases where the complaint for violation of labor standard laws preceded the termination of the employee and the filing of the illegal dismissal case, it would not be in consonance with justice to charge the complainants with engaging in forum shopping when the remedy available to them at the time their causes of action arose was to file separate cases before different fora.”^[23]

The Court’s decision provides clarity on the circumstances under which employees can file separate labor-related cases without being accused of forum shopping. It affirms that if the causes of action are distinct and fall under the jurisdiction of different bodies, the filing of separate cases is permissible. The following table summarizes the key differences between the two cases filed by the employees:

Case Filed	Cause of Action	Jurisdiction
DOLE Case	Underpayment of wages and non-payment of labor standard benefits	Department of Labor and Employment (DOLE)
NLRC Case	Illegal dismissal	National Labor Relations Commission (NLRC)

The Supreme Court’s ruling in this case is a significant victory for employees, as it protects their right to seek redress for labor violations and illegal dismissal without fear of being penalized for forum shopping. By clarifying the distinction between cases falling under the jurisdiction of the DOLE and the NLRC, the Court has ensured that employees are not unfairly restricted in pursuing their legitimate claims.

FAQs

What was the key issue in this case?	The key issue was whether the employees committed forum shopping by filing separate cases with the DOLE for labor standard violations and with the NLRC for illegal dismissal.
What is forum shopping?	Forum shopping is the act of repetitively seeking judicial remedies in different courts or administrative agencies based on the same facts and issues to obtain a favorable decision. It is considered an abuse of the judicial process.
Why did the employees file cases with both the DOLE and the NLRC?	The employees initially filed a case with the DOLE for labor standard violations. After being terminated, they filed a separate case with the NLRC for illegal dismissal, as termination cases fall under the NLRC’s jurisdiction.
How did the Supreme Court rule on the issue of forum shopping?	The Supreme Court ruled that the employees did not commit forum shopping because the two cases involved distinct causes of action and fell under the jurisdiction of different bodies.
What is the significance of the DOLE case being withdrawn?	The withdrawal of the DOLE case after the filing of the NLRC case demonstrated the employees’ intent not to pursue overlapping remedies, further supporting the argument against forum shopping.
What was the Court’s basis for distinguishing between the DOLE and NLRC cases?	The Court distinguished between the cases based on the distinct causes of action: labor standard violations (DOLE) and illegal dismissal (NLRC). These fall under different jurisdictions as prescribed by the Labor Code.
What was the ruling in Consolidated Broadcasting System v. Oberio, and how did it apply?	The ruling in Consolidated Broadcasting System v. Oberio stated that it is unjust to charge complainants with forum shopping when they file separate cases before different bodies due to different causes of action. This was applied to justify the employees’ actions in this case.
What is the practical implication of this ruling for employees?	This ruling protects employees’ rights to seek redress for labor violations and illegal dismissal without being unfairly penalized for forum shopping, ensuring they can pursue legitimate claims in appropriate forums.

In conclusion, the Supreme Court’s decision underscores the importance of distinguishing between different causes of action in labor-related cases. The ruling clarifies that employees are not engaging in forum shopping when they file separate cases with the DOLE and the NLRC if those cases involve distinct legal issues and fall under the respective jurisdictions of those bodies. This decision safeguards employees’ rights to seek redress for labor violations and illegal dismissal, promoting a fairer and more just labor environment.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: KAPISANANG PANGKAUNLARAN NG KABABAIHANG POTRERO, INC. VS. REMEDIOS BARRENO, G.R. No. 175900, June 10, 2013