7/28/2019 Eduardo Brillantes vs Leonardo Castro

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Eduardo Brillantes vs. Leonardo CastroGr. No. L-9223 June 30, 1956

Facts: On December 1, 1953, Brillantes filed a complaint against Castro before the WageAdministration Service (WAS) for the recovery of the alleged unpaid salary and overtime pay.

On February 15, 1954 Brillantes and Castro entered into an Arbitration Agreement whereby theyagreed 1. That they submit their case to the WAS for investigation; and 2. That they bindthemselves to abide by whatever decision WAS may render over the case; and that theyrecognize said decision to be final and conclusive.

WAS ruling: the claim for overtime and underpayment is hereby dismissed but the respondent isadjudged to pay the claimant P50.88 corresponding to his salary for services rendered in themonth of November.

No appeal was taken from this decision and on November 10, 1954, Brillantes filed acomplaint against Castro with this Court over the same subject matter and cause of action

litigated between them before and decided by the WAS. The counsel of Brillantes agreed that thedecision rendered by the hearing officer of the WAS is an order issued pursuant to section 7 of Minimum Wage Law in relation section 12 which authorizes delegation by the Secretary of Labor of his powers in the administration or enforcement of the MWL to the Chief of the WAS,however he contends that the right to go to the Supreme Court for review of said order granted

by section 7 of MWL is not exclusive because under said section the review by this Tribunal islimited to question of law and that the findings of fact contained in the appealed decision must beaccepted.

Trial Court ruling: dismissed the complaint on the ground that it is barred by prior judgment.Hence, this appeal.

Issue: whether or not, the second complaint is barred by prior judgment.

Held: affirmative; the SC fully agree with the decision of the trial court that the complaint is barred by prior judgment. There is no question that the complaint filed by Brillantes with theWAS may be regarded as a suit by one party as against another to enforce a right; that the WASin entertaining said suit, hearing the parties and deciding the case acted as quasi-judicial bodyand the proceedings before it were quasi-judicial proceedings, and conducted in accordance withlaw, and so was the decision rendered. The failure of Brillantes to appeal from said decision tothe SC as provided by the Minimum wage law rendered it final and conclusive and served as a

bar to another action between the same parties involving the same subject matter and cause of action and the same issues. Besides, the parties signed an agreement whereby they submittedtheir case to the WAS, binding themselves to abide by whatever decision it would validly render.

Note: the principle of res judicata is applicable to decisions of a quasi-judicial body like theWAS. In this connection, it has been declared that whatever a final adjudication of personsinvested with power to decide on the property and rights of the citizen is examinable by the SC,upon a writ of error or a certiorari; such final adjudication may be pleaded as res judicata.