Case Digest (G.R. No. 193816) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Erson Ang Lee Doing Business as “Super Lamination Services” v. Samahang Manggagawa ng Super Lamination (SMSLSA-NAFLU-KMU), petitioner Erson Ang Lee operates Super Lamination Services as a sole proprietorship, while Express Lamination Services, Inc. and Express Coat Enterprises, Inc. are separate SEC-registered corporations under his control. On March 7, 2008, three affiliated unions—Union A (Super Lamination), Union B (Express Lamination), and Union C (Express Coat)—filed separate Petitions for Certification Election with the Department of Labor and Employment (DOLE) to represent the rank-and-file employees of each entity. DOLE mediators denied all petitions on the ground of no employer-employee relationship, prompting consolidated appeals to the DOLE Secretary. Undersecretary Romeo C. Lagman reversed those orders on May 8, 2009, finding that the three companies shared a common human resources department, rotated employees among them, and operated under a work-pooling scheme Case Digest (G.R. No. 193816) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Structure
- Petitioner Erson Ang Lee operates Super Lamination Services as a sole proprietorship.
- Express Lamination Services, Inc. and Express Coat Enterprises, Inc. are separate SEC-registered corporations.
- All three entities share common ownership and management under Ang Lee.
- Unions and Certification Election Petitions
- On 7 March 2008, Samahan ng mga Manggagawa ng Super Lamination Services (Union A) filed a petition for certification election to represent Super Lamination rank-and-file employees.
- On the same date, Express Lamination Workers’ Union (Union B) and Samahan ng mga Manggagawa ng Express Coat Enterprises, Inc. (Union C) filed similar petitions for Express Lamination and Express Coat employees, respectively.
- Motion to Dismiss and DOLE Proceedings
- The three companies, represented by the same counsel, moved to dismiss each petition, contending lack of employer-employee relationship and alternately asserting that employees belonged to sister companies.
- DOLE NCR Mediator-Arbiters denied Unions B and C on 21 May 2008 and Union A on 23 May 2008 for lack of employer-employee relationship.
- Appeals and DOLE Secretary Decision
- The unions consolidated their appeals before the DOLE Secretary.
- Undersecretary Lagman reversed and set aside the DOLE NCR orders and directed certification elections covering all rank-and-file employees of the three entities.
- DOLE found the three entities to be sister companies under a work-pooling scheme with a common human resource department, single ID issuance, shared payroll and SSS registrations, and constant rotation of workers.
- DOLE applied the concept of multi-employer bargaining under DOLE Department Order No. 40-03, finding a single bargaining unit appropriate.
- Court of Appeals and Supreme Court Petition
- The Court of Appeals affirmed the DOLE Secretary’s decision, endorsing the work-pooling and multi-employer bargaining findings.
- Petitioner’s motion for reconsideration was denied.
- Petitioner filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether piercing the corporate veil of Express Lamination Services, Inc. and Express Coat Enterprises, Inc. is warranted.
- Whether the rank-and-file employees of the three entities constitute an appropriate bargaining unit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)