Case Digest (G.R. No. 46530) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rodel F. Bantogon v. PVC Master Mfg. Corp., petitioner Rodel F. Bantogon filed a complaint for illegal dismissal against respondent PVC Master Manufacturing Corporation (“PVC”). On May 20, 2012, Bantogon began working for Boatwin International Corporation as a helper and was later promoted to machine operator. In January 2014, Boatwin purportedly changed its trade name to PVC, which allegedly commenced operations on February 14, 2014. In March 2014, Bantogon was barred from reporting for work after PVC learned of his participation in his brother’s illegal dismissal case against the same company. He claimed that this refusal to assign him work amounted to constructive dismissal without due process or just cause. PVC, however, contended it was a separate corporate entity, having acquired Boatwin’s assets through an alleged sale, and denied ever employing Bantogon. The Labor Arbiter, by Decision dated August 29, 2014, found PVC guilty of illegal dismissal and ordered reinstateme... Case Digest (G.R. No. 46530) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On May 20, 2012, petitioner Rodel F. Bantogon was hired by Boatwin International Corporation as a helper and later promoted to machine operator.
- In January 2014, Boatwin changed its trade name to PVC Master Manufacturing Corporation (PVC), which commenced operations on February 14, 2014.
- In March 2014, petitioner was barred from reporting for work allegedly due to his participation in his brother’s illegal dismissal case against PVC, resulting in constructive termination and alleged failure to observe due process.
- Administrative and Judicial Proceedings
- Position Papers
- June 24, 2014 – Petitioner alleged continuous employment from Boatwin to PVC and illegal dismissal without due process.
- PVC denied any employer-employee relationship, claimed to be a separate entity from Boatwin, and submitted corporate documents (Mayor’s Permit, SEC registrations, articles of incorporation, etc.).
- Labor Arbiter Decision (August 29, 2014)
- Found PVC guilty of illegal dismissal; ruled petitioner was absorbed by PVC when it assumed Boatwin’s business.
- Awarded backwages, separation pay, wage differentials, unpaid 13th month pay, and attorney’s fees.
- NLRC Decision (November 28, 2014) and Resolution (January 21, 2015)
- NLRC affirmed the Labor Arbiter, holding that petitioner was PVC’s employee and was illegally dismissed.
- Denied PVC’s motion for reconsideration.
- Court of Appeals Proceedings
- CA Decision (November 24, 2017) – Reversed NLRC, ruling that petitioner failed to prove employment with PVC; held that an alleged asset sale relieved PVC of absorbing Boatwin’s employees.
- CA Resolution (May 8, 2018) – Denied petitioner’s motion for reconsideration.
- Present Petition
- Petitioner filed a petition for review on certiorari under Rule 45, contending that the CA erred in finding no employer-employee relationship and that PVC was merely a continuation of Boatwin, liable for its debts and obligations, including illegal dismissal.
- Issue certified by the Supreme Court: Did the CA commit reversible error in ruling that petitioner was not an employee of PVC?
Issues:
- Whether the Court of Appeals erred in holding that petitioner failed to establish an employer-employee relationship with PVC.
- Whether PVC, by virtue of a mere change of corporate name or alleged asset sale, is relieved of liabilities incurred under Boatwin, including the illegal dismissal claim.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)