Case Digest (G.R. No. 69494)
Facts:
The case revolves around A.C. Ransom Labor Union-CCLU as the petitioner against the National Labor Relations Commission (NLRC) and A.C. Ransom (Philippines) Corporation, among other respondents. A.C. Ransom (Philippines) Corporation, founded in 1933 by Maximo C. Hernandez, Sr., is a family corporation primarily engaged in the manufacturing of ink and related products, located in Las Piñas, Rizal. On June 6, 1961, employees including many union members initiated a strike which was lifted by June 21, allowing most strikers to return to work. However, 22 strikers were denied reinstatement. The strike led to the filing of Cases Nos. 2848-ULP and 2880-ULP in the Court of Industrial Relations, resulting in a December 19, 1972 decision mandating RANSOM to reinstate the strikers with back wages starting from July 25, 1969.
On April 2, 1973, RANSOM applied for closure, granted by the Ministry of Labor and Employment, although the company retained its corporate identity. The computed back
Case Digest (G.R. No. 69494)
Facts:
Establishment and Nature of RANSOM:
- Respondent A.C. Ransom (Philippines) Corporation (RANSOM) was established in 1933 by Maximo C. Hernandez, Sr. It was a family corporation, with stockholders being members of the Hernandez family. The company was engaged in the manufacture of ink and related products in Las Piñas, Rizal.
1961 Strike and Reinstatement Issues:
- On June 6, 1961, employees of RANSOM, mostly members of petitioner A.C. Ransom Labor Union-CCLU, went on strike. The picket line was lifted on June 21, 1961, with most strikers returning to work. However, 22 strikers were refused reinstatement by RANSOM.
Formation of ROSARIO Industrial Corporation:
- In 1969, the Hernandez family organized Rosario Industrial Corporation (ROSARIO), which also engaged in the manufacture of ink and related products within the RANSOM compound.
Court of Industrial Relations Decision (1972):
- The strike led to Cases Nos. 2848-ULP and 2880-ULP before the Court of Industrial Relations (CIR). On December 19, 1972, the CIR ordered RANSOM to reinstate the 22 strikers with back wages from July 25, 1969.
RANSOM’s Closure and Execution Issues:
- On April 2, 1973, RANSOM applied for clearance to cease operations, which was granted effective May 1, 1973. Despite ceasing operations, RANSOM retained its corporate personality. Reinstatement of the 22 strikers became impracticable.
- Back wages for the 22 strikers were computed at P164,984.00 in early 1974.
- Petitioner UNION filed multiple motions for execution against RANSOM, but these were unsuccessful due to the company’s lack of leviable assets. Notably, RANSOM sold machinery and equipment for P2 million in 1975.
Motion for Execution Against Officers (1978):
- On December 18, 1978, petitioner UNION filed a motion for execution, seeking to hold RANSOM’s officers and agents personally liable for the back wages. Labor Arbiter Tito F. Genilo granted the motion on March 11, 1980, authorizing a writ of execution against RANSOM and its seven officers and directors.
NLRC Decision (1984):
- RANSOM appealed to the National Labor Relations Commission (NLRC), which affirmed the Genilo Order but modified it by excluding personal liability of the officers and agents.
Issue:
Enforceability of the 1972 Decision:
- Whether the 1972 CIR decision, which became final and executory in 1973, could still be enforced by a writ of execution issued in 1980, more than five years after its finality.
Personal Liability of Corporate Officers:
- Whether the judgment against RANSOM for reinstatement and back wages could be enforced against its officers and agents in their individual capacities, despite not being parties to the original case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court set aside the NLRC’s decision and reinstated the Labor Arbiter’s Order, with the modification that personal liability for the back wages of the 22 strikers was limited to Ruben Hernandez (President in 1974) and subsequent presidents of RANSOM.