Case Digest (G.R. No. 117932)
Facts:
Avon Dale Garments, Inc. v. National Labor Relations Commission, G.R. No. 117932, July 20, 1995, Supreme Court Third Division, Francisco, J., writing for the Court.Petitioner Avon Dale Garments, Inc. sought certiorari to set aside the National Labor Relations Commission’s (NLRC) August 31, 1994 decision in NLRC CA 005068-93, asserting grave abuse of discretion. The dispute arose from a previous employment-rotation conflict between the petitioner (and its predecessor) and several employees (private respondents), which resulted in a compromise agreement terminating the private respondents and awarding separation pay.
When petitioner refused to include the private respondents’ years of service under Avon Dale Shirt Factory (the predecessor) in computing separation pay, the employees filed a complaint for deficiency in separation pay with the labor arbiter (docketed NLRC-NCR-00-02-00810-93). The labor arbiter, in a May 14, 1993 decision, dismissed the complaint after finding that Avon Dale Shirt Factory had been dissolved on December 27, 1978 by filing Articles of Dissolution with the Securities and Exchange Commission.
The private respondents appealed to the NLRC, which reversed the labor arbiter on August 31, 1994, concluding that even though the predecessor had filed Articles of Dissolution, there was no showing that its terminated employees—creditors as to separation pay—were paid; hence, Avon Dale Garments, Inc. as successor-in-interest was liable for the unpaid claims. Petitioner invoked certiorari before the Supreme Court to annul the NLRC ruling.
While the petition was pending, counsel for private respondents filed a Manifestation claiming the parties had settled on December 27, 1994 and executed a waiver and quitclaim after payment. The Office of the Solicitor General verified that the compromise was executed without the knowledge and participation of the NLRC. The Court noted the rule, under Atilano v. De la Cruz, that compromise ag...(Subscriber-Only)
Issues:
- Is the compromise agreement between the parties binding and enforceable despite lacking the NLRC’s participation in violation of the rule requiring presence of the Regional Director?
- Did the NLRC commit grave abuse of discretion in holding Avon Dale Garments, Inc. liable as successor-in-interest for the private respondents’ separation pay, i.e., is Avon Dale Garments a separate and distinct e...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)