Case Digest (G.R. No. 238477) Core Legal Reasoning Model
Facts:
In G.R. No. 238477, Ronnie Adriano R. Amoroso and Vicente R. Constantino, Jr. (petitioners) filed a Complaint on December 13, 2016 for illegal dismissal and nonpayment of salary and overtime pay against Vantage Drilling International and Group of Companies (formerly Vantage Drilling Company and Group of Companies) and its affiliates: (1) Vantage International Payroll Company Pte. Ltd. (Vantage Payroll), (2) Vantage International Management Co. Pte. Ltd. (Vantage Management), and (3) Vantage Driller III Company (Vantage Company), doing business in the Philippines through resident agent Supply Oilfield Services, Inc. represented by Louis Paul Heusaff. Petitioners claimed employment as administrators to be deployed in West Africa—Amoroso by Vantage Payroll since April 29, 2010, and Constantino by Vantage Management since July 10, 2011—working 42 consecutive days of at least 12 hours daily without overtime pay, followed by 21 days’ rest, culminating in an aggregate of 252 work days
Case Digest (G.R. No. 238477) Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Structure
- Petitioners
- Ronnie Adriano R. Amoroso – employed as administrator by Vantage International Payroll Company Pte. Ltd. (“Vantage Payroll”) from April 29, 2010; deployed in West Africa.
- Vicente R. Constantino, Jr. – employed as administrator by Vantage International Management Co. Pte. Ltd. (“Vantage Management”) from July 10, 2011; deployed in West Africa.
- Respondents
- Vantage Drilling International and Group of Companies (“Vantage International”) – Cayman Islands corporation; provides offshore drilling services.
- Vantage International Payroll Company Pte. Ltd. (“Vantage Payroll”) – Singaporean corporation; payroll services.
- Vantage International Management Co. Pte. Ltd. (“Vantage Management”) – Singaporean corporation; oil and gas services.
- Vantage Drilling Company (licensed branch in the Philippines as Vantage Driller III Company) – Cayman Islands corporation; resident agent Supply Oilfield Services, Inc., represented by Louis Paul Heusaff.
- Employment Conditions and Grievances
- Work Schedule and Nonpayment
- From July 2011 to September 2013, both petitioners worked 42 consecutive days of at least 12 hours/day, followed by 21 rest days, totaling 252 workdays.
- Petitioners alleged nonpayment of regular wages and overtime.
- Termination and Subsequent Events
- December 11, 2015 – verbal notice of redundancy-based termination; formal email followed.
- Petitioners protested lack of actual redundancy and sought redundancy package.
- December 20–22, 2015 – Amoroso demanded overtime pay; was suspended, repatriated, and summoned to a disciplinary hearing.
- January 12, 2016 – Amoroso summarily dismissed for alleged gross misconduct.
- Procedural History
- Labor Arbiter (April 24, 2017 Decision)
- Dismissed complaint for lack of jurisdiction over Vantage Payroll and other foreign entities not validly served.
- National Labor Relations Commission (June 27, 2017 Decision; August 11, 2017 Resolution)
- Affirmed dismissal; denied motion for reconsideration.
- Court of Appeals (November 28, 2017 and March 16, 2018 Resolutions)
- Dismissed petition for certiorari; upheld lower tribunals on lack of personal jurisdiction.
- Supreme Court (G.R. No. 238477, August 8, 2022)
- Petition for review on certiorari filed by petitioners seeking reversal and solidary liability via piercing corporate veil.
Issues:
- Jurisdiction
- Whether the Labor Arbiter and subsequent bodies acquired personal jurisdiction over Vantage International, Vantage Payroll, and Vantage Management through service of summons upon the resident agent of Vantage Drilling Company.
- Whether the doctrine of piercing the corporate veil may be invoked to confer jurisdiction over entities not validly served or appearing.
- Liability
- Whether all respondents may be held solidarily liable for illegal dismissal and nonpayment of benefits by treating them as a single employer under the piercing-the-veil doctrine.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)