DOLE PH v. Esteva

Dole PH v. Esteva, G.R. No. 161115.
November 30, 2006
Facts: Petitioner is a corporation engaged principally in the production and processing of pineapple for
the export market. Respondents are members of the Cannery Multi-Purpose Cooperative (CAMPCO).
CAMPCO members rendered services to the petitioner under a Service Contract. Although the Service
Contract specifically stated that it shall only be for a period of six months (from July 1 to December 31,
1993), the parties had apparently extended or renewed the same for succeeding years without
executing another written contract. It was under these circumstances that respondents came to work
for petitioner.
DOLE organized a Task Force that investigated in the alleged labor-only contracting activities of the
cooperatives. The Task Force identified six cooperatives that were engaged in labor-only contracting,
one of which was CAMPCO. Consequently, a case ensued which led the issuance of DOLE an order
against respondents to cease and desist from further engaging in activities involving DOLE PH’s principal
business. Respondents appealed said order alleging that there was serious error of law in directing the
cooperatives to cease and desist from engaging in labor-only contracting but was dismissed.
Respondents further claimed entitlement to wage differential, moral damages, and attorney's fees.
The NLRC ruled in favor of DOLE PH; hence respondents’ appeal to the CA through a review on certiorari
The CA ruled in favor of respondents, that they were employees of DOLE PH all along and petitioner is
guilty of illegal employment; hence, DOLE PH’s present petition to the SC.
Issue: Whether or not the rulings of the DOLE and NLRC has the force and effect of law; YES.
Ruling: It is obvious that the visitorial and enforcement power granted to the DOLE Secretary is in the
nature of a quasi-judicial power. Quasi-judicial power has been described by this Court in the following
manner —
Quasi-judicial or administrative adjudicatory power on the other hand is the power of the administrative
agency to adjudicate the rights of persons before it. It is the power to hear and determine questions of
fact to which the legislative policy is to apply and to decide in accordance with the standards laid down
by the law itself in enforcing and administering the same law. The administrative body exercises its quasi-
judicial power when it performs in a judicial manner an act which is essentially of an executive or
administrative nature, where the power to act in such manner is incidental to or reasonably necessary for
the performance of the executive or administrative duty entrusted to it . In carrying out their quasi-judicial
functions the administrative officers or bodies are required to investigate facts or ascertain the existence
of facts, hold hearings, weigh evidence, and draw conclusions from them as basis for their o􀁍cial action
and exercise of discretion in a judicial nature. Since rights of specific persons are affected it is elementary
that in the proper exercise of quasi-judicial power due process must be observed in the conduct of the
proceedings. (Emphasis supplied.)
The DOLE Secretary, under Article 106 of the Labor Code, as amended, exercise quasi-judicial power, at
least, to the extent necessary to determine violations of labor standards provisions of the Code and other
labor legislation. He can issue compliance orders and writs of execution for the enforcement of his orders.
The Orders of DOLE Regional Director Parel, dated 19 September 1993, and of DOLE Undersecretary
Trajano, dated 15 September 1994, consistently found that CAMPCO was engaging in labor-only
contracting. Such finding constitutes res judicata in the case filed by the respondents with the NLRC.
It is well-established in this jurisdiction that the decisions and orders of administrative agencies,
rendered pursuant to their quasi-judicial authority, have upon their finality, the force and binding effect
of a final judgment within the purview of the doctrine of res judicata. The rule of res judicata, which
forbids the reopening of a matter once judicially determined by competent authority, applies as well to
the judicial and quasi-judicial acts of public, executive or administrative officers and boards acting within
their jurisdiction as to the judgments of courts having general judicial powers.
The orderly administration of justice requires that the judgments or resolutions of a court or quasi-judicial
body must reach a point of finality set by the law, rules and regulations, so as to writefinis to disputes
once and for all. This is a fundamental principle in the Philippine justice system, without which there would
be no end to litigations.

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Dole PH v. Esteva, G.R. No. 161115.

November 30, 2006

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