Case Digest (G.R. No. 69494) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.C. Ransom Labor Union-CCLU vs. National Labor Relations Commission, the Court of Industrial Relations (CIR) on August 19, 1972 found A.C. Ransom (Phils.) Corporation guilty of unfair labor practice—interference and discrimination—against 22 union members, including Ruben Hernandez, Maximo C. Hernandez, Jr., Porfirio N. Valencia, Laura H. Cornejo, Francisco Hernandez, Celestino C. Hernandez, and Ma. Rosario Hernandez, who had legally struck. The CIR ordered the immediate reinstatement of these employees with backwages from July 25, 1969 until actual reinstatement. This Decision was affirmed by the Supreme Court on February 26, 1973 (G.R. Nos. L-36226-68). An examiner computed the backwages at ₱199,276.00, later reduced to ₱164,984.00 after motions for execution and recomputation. Meanwhile, Ransom obtained a clearance from the Secretary of Labor on June 7, 1973 to cease operations effective May 1, 1973, but failed to satisfy the award. In 1969, the same family organized a ne Case Digest (G.R. No. 69494) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial adjudication of unfair labor practices
- August 19, 1972 CIR joint Decision
- A.C. Ransom (Phils.) Corp. found guilty of interference and discrimination.
- Strike declared legal and justified; ordered reinstatement of 22 employees with backwages from July 25, 1969.
- Supreme Court denial of Ransom’s petition for review (Feb. 26, 1973)
- CIR Decision became final and executory.
- Backwages originally computed at ₱199,276.00, later recomputed to ₱164,984.00.
- Cessation of Ransom operations and creation of Rosario Industrial
- Secretary of Labor clearance (June 7, 1973)
- Ransom permitted to cease operations effective May 1, 1973 due to financial difficulties.
- Clearance without prejudice to employees’ rights to seek redress.
- Union’s allegation of “run-away” corporation (Jan. 21, 1974)
- Forbes same Hernandez family officers organized Rosario Industrial in 1969.
- Rosario used identical equipment, premises, personnel and business lines to evade backwages.
- Execution and enforcement proceedings
- Multiple motions for execution (1973–1977) and writs issued (June 23, 1976; Feb. 17, 1977) without satisfaction.
- Labor Arbiter Tito F. Genilo’s Order (Mar. 11, 1980)
- Declared Ransom officers and agents personally liable for ₱164,984.00.
- Named seven respondents, though some had died (e.g., Ma. Rosario Hernandez 1971).
- Appeals and Supreme Court resolutions
- NLRC Decision relieving officers/agents of personal liability (1980) on grounds of lack of authority‐exceeding acts and absence of hearing.
- Supreme Court Decision (June 10, 1986)
- Set aside NLRC ruling; reinstated Arbiter’s Order with liability limited to Ransom President(s).
- Both parties filed motions for reconsideration.
- Final Supreme Court Decision (May 29, 1987)
- Denied private respondents’ motion; granted union’s motion in part.
- Modified disposition to impose joint and several liability on Rosario Industrial and surviving officers.
Issues:
- Whether corporate officers and agents can be held personally liable for backwages under a final and executory CIR Decision.
- Whether Rosario Industrial, a separately incorporated entity using identical assets and management, should be held liable under the doctrine of piercing the corporate veil.
- Applicability of workers’ first preference in bankruptcy or liquidation over other creditors for unpaid wages.
- Scope of enforcement of final labor awards through successive execution proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)