Title
Amoroso vs. Vantage Drilling International and Group of Companies
Case
G.R. No. 238477
Decision Date
Aug 8, 2022
Employees alleged unpaid wages, overtime, and illegal dismissal by foreign-based employers; jurisdiction over respondents not acquired due to improper summons.

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)

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