ROBERTO ILAO HORNILLA, PETITIONER, VS. NATIONAL LABOR RELATIONS COMMISSION (FIRST DIVISION), PHILIPPINE TRANSMARINE CARRIERS, INC., STENA MARINE MGT. PTE. LTD. / NORTHERN MARINE…

Hornilla versus National Labor Relations Commission

The Case

This is Hornilla versus National Labor Relations Commission, a labor case that reached the Supreme Court by petition for certiorari but was never decided on the merits. The petitioner, Roberto Ilao Hornilla, sued the National Labor Relations Commission together with Philippine Transmarine Carriers, Incorporated, Stena Marine Management Private Limited, and Northern Marine, arising from a maritime employment dispute. The case matters to a reviewee for one reason above all: it is a clean illustration of how a pending case ends when the parties settle. The Court did not reach the merits because the parties filed a joint manifestation with a motion to dismiss grounded on an amicable settlement. What the Court teaches here is procedural: a compromise extinguishes the controversy, and the Court will dismiss the petition with prejudice and consider the case closed and terminated.

Procedural History

The dispute began in the labor tribunals and produced an adverse ruling that Hornilla brought up to the Court of Appeals by a petition for certiorari, docketed there as a special civil action. The Court of Appeals did not resolve that petition on its merits. Instead, Hornilla and the private respondents, through counsel, filed with the Supreme Court a Joint Manifestation with Motion to Dismiss the instant Petition for Certiorari, dated January 22, 2014 as noted in the text, praying for dismissal on the ground that the parties concerned had amicably settled the case. Attached to the manifestation were several annexes, namely the Satisfaction of Judgment and Joint Motion to Dismiss, the Release of All Rights, the Pagpapaubaya ng Lahat ng Karapatan, the Affidavit of Claimant, and the Receipt of Payment, all dated January 22, 2015. Finding the joint manifestation meritorious, the Court dismissed the petition with prejudice and declared the case closed and terminated.

Facts

Roberto Ilao Hornilla was the petitioner in a labor dispute against Philippine Transmarine Carriers, Incorporated and its co-respondents, Stena Marine Management Private Limited and Northern Marine. The dispute was litigated in the labor tribunals and then elevated to the Court of Appeals by a petition for certiorari, docketed as a special civil action.

While the case was pending, the parties reached an amicable settlement. On February 23, 2015, Hornilla and the private respondents, through counsel, filed with the Supreme Court a Joint Manifestation with Motion to Dismiss the instant Petition for Certiorari, praying that the petition be dismissed because the parties concerned had amicably settled the case.

The manifestation was supported by annexes showing that the settlement had in fact been carried out: a Satisfaction of Judgment and Joint Motion to Dismiss, a Release of All Rights, a Pagpapaubaya ng Lahat ng Karapatan, an Affidavit of Claimant, and a Receipt of Payment, all dated January 22, 2015. On that record, the Court found the joint manifestation meritorious.

Issues

• Whether or not the petition for certiorari should be dismissed on the ground that the parties had amicably settled the case.
• Whether or not the dismissal should be with prejudice, with the case considered closed and terminated.

Applicable Provisions

The decision is a short resolution and quotes no statutory provision. It rests on the parties' joint manifestation and motion to dismiss grounded on an amicable settlement, supported by the Satisfaction of Judgment, the Release of All Rights, the Pagpapaubaya ng Lahat ng Karapatan, the Affidavit of Claimant, and the Receipt of Payment. No article of the Labor Code or the Rules of Court is quoted or construed in the text, so none is reproduced here.

Ruling

On the first issue, the Court granted the motion. Finding the Joint Manifestation with Motion to Dismiss the Instant Petition for Certiorari to be meritorious, it dismissed the petition. The basis was the parties' own representation that they had amicably settled the case, supported by the annexes evidencing satisfaction and release. The Court did not examine the merits of the labor dispute at all.

On the second issue, the Court ordered that the dismissal be with prejudice. It further declared that the petition, docketed in the Court of Appeals as a special civil action, is considered closed and terminated. The dismissal with prejudice means the controversy is finally laid to rest and cannot be revived.

Doctrine

A Bar candidate should retain these rules. First, an amicable settlement between the parties in a pending case is a ground for dismissal of the petition, and the Court will act on a joint manifestation supported by proof of satisfaction and release. Second, where the dismissal rests on such a settlement, the dismissal is with prejudice, and the case is considered closed and terminated. Third, the Court will not pass upon the merits of a controversy that the parties themselves have extinguished by compromise. These rules are procedural rather than statutory, drawn from the parties' joint manifestation and the annexes attached to it, not from any quoted provision.

Disposition

The Court dismissed the petition with prejudice on the ground of the parties' amicable settlement and declared the case closed and terminated.

Remember This

The line worth memorizing is that a case amicably settled by the parties is dismissed with prejudice and considered closed and terminated. Examiners use this case to test whether a reviewee recognizes compromise and satisfaction of judgment as a ground for dismissal that ends the controversy for good.