Facts:

The case involves petitioners Ronnie Adriano R. Amoroso and Vicente R. Constantino, Jr. (the petitioners) against Vantage Drilling International and Group of Companies (formerly Vantage Drilling Company and Group of Companies), along with its affiliates: Vantage International Management Co. Pte. Ltd., Vantage International Payroll Company Pte. Ltd., and Vantage Driller III Company (collectively referred to as the respondents). The events leading to this case began when the petitioners filed a complaint for illegal dismissal and nonpayment of salaries and overtime pay against the respondents on December 13, 2016. The petitioners claimed that they had been employed to work in West Africa but had not been compensated for their extensive hours worked, allegedly exceeding 252 days, over a two-year period. They also alleged that they were informed about their contract termination verbally on December 11, 2015, followed by an email notification, both claiming redundancy as the reason.

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Facts:

Background of the Case

• Petitioners Ronnie Adriano R. Amoroso and Vicente R. Constantino, Jr. filed a Complaint for illegal dismissal and nonpayment of salary and overtime pay.
• The Complaint was originally filed against Vantage Drilling International and Group of Companies (Vantage International) and its affiliates, namely:
• Vantage International Payroll Company Pte. Ltd. (Vantage Payroll)
• Vantage International Management Co. Pte. Ltd. (Vantage Management)
• Vantage Drilling Company (Vantage Company), later doing business as Vantage Driller III Company
• Supply Oilfield Services, Inc., represented by its Chairman and CEO Louis Paul Heusaff, was impleaded as the resident agent of Vantage Company.

Organizational and Operational Structure of the Respondents

• Vantage International and Vantage Company are incorporated under the laws of the Cayman Islands, with the latter licensed to establish a branch office in the Philippines.
• Vantage Payroll and Vantage Management are incorporated under Singaporean laws and provide distinct services (payroll and oil and gas services, respectively).
• Despite the different corporate entities, petitioners asserted that the respondents operated as one, having identical sets of officers, head office, tools of trade, and even the same website.

Employment and Alleged Violations

• Petitioners were employed as administrators deployed to West Africa; Amoroso by Vantage Payroll (since April 29, 2010) and Constantino by Vantage Management (since July 10, 2011).
• Both petitioners allegedly worked for 42 consecutive days (at least 12 hours each day) from July 2011 to September 2013, without receiving their due wages, overtime, or redundancy package.
• On December 11, 2015, they were verbally notified about termination on the ground of redundancy, followed by a formal email confirming termination.
• Amoroso protested the termination demanding overtime pay and, after further proceedings—including suspension with full pay, a disciplinary hearing, and a Letter alleging disruptive behavior—he was summarily dismissed for gross misconduct effective January 12, 2016.

Procedural History

• The Labor Arbiter dismissed the petitioners’ Complaint on the ground of lack of jurisdiction over Vantage Payroll, as it was not a legal personality in the Philippines.
• The National Labor Relations Commission (NLRC) affirmed, in its June 27, 2017 Decision, the Labor Arbiter’s ruling and dismissed the appeal.
• A subsequent Motion for Reconsideration by petitioners seeking to hold all respondents solidarily liable under the doctrine of piercing the corporate veil was also denied by the NLRC on August 11, 2017.
• Petitioners elevated the case to the Court of Appeals via a Petition for Certiorari, asserting that due to the service of summons upon Supply Oilfield (resident agent of Vantage Company), jurisdiction over all Vantage affiliates had been acquired.
• The Court of Appeals, through its Resolution, upheld the dismissal due to the lack of proper service and thus absence of jurisdiction over Vantage International, Vantage Payroll, and Vantage Management.
• The petitioners eventually filed a Petition for Review on Certiorari before the Supreme Court, challenging the jurisdictional ruling and advocating the application of the piercing of the corporate veil doctrine.

Service of Summons and Jurisdictional Concerns

• Under the Revised Corporation Code and the Rules of Court, service of summons on a foreign corporation may be effected through its resident agent if licensed or operating in the Philippines.
• Among the respondents, only Vantage Company was served through its resident agent (Supply Oilfield).
• There was no evidence that the other respondents (Vantage International, Vantage Payroll, and Vantage Management) were properly served or licensed to transact business in the Philippines.
• Petitioners conceded during appellate proceedings that the lower tribunals never acquired jurisdiction over the aforementioned entities.

Invocation of the Piercing Doctrine

• Petitioners argued that the separate corporate personalities were a mere facade masking a single enterprise and therefore invoked the doctrine of piercing the corporate fiction to hold all respondents solidarily liable.
• They contended that since all respondents shared identical control, operations, and even officers, the service of summons on one (via the resident agent of Vantage Company) should suffice for all.
• However, both lower tribunals maintained that the doctrine of piercing the corporate fiction applies only after jurisdiction is validly acquired, not as a means to confer jurisdiction over entities that have not been properly served.

Issue:

Jurisdictional Issue

• Whether the court or labor tribunal had acquired jurisdiction over Vantage International, Vantage Payroll, and Vantage Management given that proper service of summons was effected solely on Vantage Company through its resident agent, Supply Oilfield.
• Whether the absence of valid service of summons over the other respondents vitiates any purported jurisdiction and renders subsequent proceedings null and void.

Application of the Piercing Doctrine

• Whether the doctrine of piercing the corporate fiction can be invoked to disregard the separate legal personalities of the respondents and hold them solidarily liable without having first acquired jurisdiction over each.
• Whether using the doctrine as a means to “merge” entities—which operate as separate juridical persons—is appropriate when the requisite procedural due process (i.e., valid service of summons) has not been observed.

Due Process Considerations

• Whether any judgment, finding of liability, or order rendered in the absence of proper notification and opportunity for the respondents (owing to lack of service) is in violation of their constitutional right to due process.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)