Title
Alfante vs. National Labor Relations Commission
Case
G.R. No. 122655
Decision Date
Dec 15, 1997
Reynaldo Alfante, illegally dismissed by Pepsi-Cola Distributors (PCD), sought reinstatement and backwages. Supreme Court ruled successor-in-interest PCPPI liable, awarding full backwages and separation pay, overturning NLRC’s decision.
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Case Digest (G.R. No. 122655)

Facts:

Employment and Dismissal

  • Petitioner Reynaldo B. Alfante was employed as Maintenance Manager by Pepsi-Cola Distributors (PCD) on August 1, 1984.
  • On December 31, 1988, PCD terminated Alfante's employment on the grounds of alleged loss of trust and confidence.

Legal Proceedings

  • Alfante filed a complaint for illegal dismissal, reinstatement with backwages, and attorney’s fees against PCD before the Sub-Regional Arbitration Branch X of the NLRC in Butuan City (docketed as SRAB-10-02-00022-89).
  • On May 15, 1989, Labor Arbiter Marissa Macaraig-Guillen declared Alfante's dismissal illegal and ordered his reinstatement with full backwages, damages, and attorney’s fees.
  • PCD appealed to the NLRC (Fifth Division), which modified the decision on April 25, 1991, limiting backwages to three years and awarding separation pay in lieu of reinstatement. The award of damages was deleted, but attorney’s fees were affirmed.
  • PCD filed a petition for review before the Supreme Court, which was dismissed for non-compliance with Revised Circular No. 1-88. The NLRC decision became final and executory.

Execution of Judgment

  • On May 13, 1992, the NLRC issued an order for the issuance of a writ of execution against PCD.
  • On October 8, 1993, Alfante filed a motion for a writ of execution against Pepsi-Cola Products Philippines, Inc. (PCPPI), alleging that PCPPI was the successor-in-interest of PCD.
  • PCPPI opposed the motion, arguing that it was a separate juridical entity from PCD and was not a party to the case.

Labor Arbiter’s Ruling

  • On March 1, 1995, Labor Arbiter Rogelio Legaspi granted Alfante’s motion, ordering the issuance of a writ of execution against both PCD and PCPPI.
  • PCPPI filed a petition with the NLRC, challenging the order and seeking a temporary restraining order, which was granted on March 28, 1995.

NLRC Decision

  • On September 27, 1995, the NLRC ruled in favor of PCPPI, declaring the Labor Arbiter’s order null and void for lack of jurisdiction over PCPPI.

Issue:

  1. Whether the NLRC committed grave abuse of discretion in ruling that PCPPI has a separate and distinct personality from PCD, thereby absolving PCPPI from liability for PCD’s obligations.
  2. Whether PCPPI, as the successor-in-interest of PCD, is liable for the judgment against PCD.
  3. Whether the computation of backwages and the award of separation pay were proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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