SSC vs Rizal Poultry

Doctrine of conclusiveness of judgment

G.R. No. 167050 (2011)

FACTS:
• Mr. Angeles filed a petition before SSC compelling Rizal
Poultry to remit to the SSS all contributions due for and in
his behalf.

• Rizal Poultry countered with a motion to dismiss by virtue of

the rulings of NLRC and CA regarding the absence of
employer-employee relationship between Mr. Angeles and
respondents, thus it is barred by res judicata.
• SSC shrugged off the said decisions of NLRC and CA
because of the absence of the indispensable element
of identity of causes of action.
> as one is for violation of SSS law (non-
remittance) and the other for violation of the
Labor code (illegal dismissal). Therefore, does not
constitute res judicata.
ISSUE:
• Whether res judicata applies.
HELD:
• YES. Res judicata by conclusiveness of judgment does not require
identity in the causes of action. Identity of issues is sufficient.
> the mandatory coverage as well the remittance of
contributions under the SSS law is premised on the existence of an
employer-employee relationship.

• Hence, the NLRC decision on the absence of employer-employee

relationship is binding in the SSC case.

*Take away: Doctrine of conclusiveness of judgment also applies in criminal cases.

 Nestle vs Uniwide
Doctrine of primary administrative jurisdiction

G.R. No. 174674 (2010)

FACTS:
• Uniwide filed in the Securities and Exchange Commission
(SEC) a petition for Rehabilitation brought under FRIA of
2010.

• SEC approved the Rehabilitation plan (RP) prepared by the

Interim Receivership Committee (IRC) anchored on return
to core business retailing; debt reduction via cash
entitlement and etc.
• The SEC approved the two amendments made to the Rehabilitation
plan. (1) The planned entry of a casino, envisioned to infuse fresh
capital (2) the Casino’s subsequent withdrawal.

• Nestle, as unsecured creditor, appealed to the SEC that the

approval of the amendment of the casino’s withdrawal be set aside
and a new one be issued directing the IRC to improve the terms
and conditions of the Rehabilitation plan. SEC, denied the appeal.
• From the time of the filing of the petition in SC, supervening
events have unfolded substantially changing the factual
backdrop of the rehabilitation case which prevented the
realization of the goals of RP, which are:

> (1) Unexpected refusal of some creditors to comply with all the
terms of the Amended RP (2) lack of supplier, and etc.
ISSUE:
• Whether the Rehabilitation plan be revoked and
the Rehabilitation proceedings terminated.
Held.
• No. Under the doctrine of primary administrative
jurisdiction, courts will not determine a controversy
where the issues for resolution demand the exercise
of sound administrative discretion requiring the
special knowledge, experience, and services of the
administrative tribunal to determine technical and
intricate matters of fact.