Title
Cacho vs. Balagtas
Case
G.R. No. 202974
Decision Date
Feb 7, 2018
A corporate officer's dismissal case, deemed an intra-corporate dispute, falls under regular courts' jurisdiction, not labor arbiters.

Case Digest (G.R. No. 202974)

Facts:

Cacho v. Balagtas, G.R. No. 202974, February 07, 2018, Supreme Court First Division, Leonardo‑De Castro, J., writing for the Court. Petitioners are Norma D. Cacho and North Star International Travel, Inc.; respondent is Virginia D. Balagtas. Balagtas filed a complaint for constructive dismissal against North Star and Cacho before the Labor Arbiter (NLRC‑NCR Case No. 04‑04736‑04), alleging that after some 14 years of service she was preventively suspended on March 19, 2004 and thereafter prevented from resuming her position, prompting her claim of constructive dismissal effective April 12, 2004.

The Labor Arbiter rendered a decision dated March 28, 2005 finding Balagtas illegally dismissed and awarding separation pay, backwages, commissions, moral and exemplary damages, and attorney’s fees. Petitioners appealed to the NLRC, arguing lack of jurisdiction on the ground that Balagtas was a corporate officer (Executive Vice President/Chief Executive Officer and incorporator/director) and that her dismissal thus involved an intra‑corporate controversy properly cognizable by the regular courts.

The NLRC, in a Resolution dated September 30, 2008, reversed and set aside the Labor Arbiter’s decision and dismissed the complaint for lack of jurisdiction, finding that Balagtas occupied a corporate office (citing board resolutions and a Secretary’s Certificate) and that corporate‑officer dismissals are intra‑corporate matters. Balagtas filed a petition for certiorari with the Court of Appeals. The Court of Appeals, in a Decision dated November 9, 2011, granted the petition, reversed the NLRC, and affirmed the Labor Arbiter’s March 28, 2005 Decision, holding that the case involved labor issues and that the Executive Vice President title did not automatically make Balagtas a corporate officer under North Star’s by‑laws.

Petitioners then brought a petition for review on certiorari under Rule 45 to the Supreme Court seeking to ...(Pro-only)

Issues:

  • Whether respondent Virginia D. Balagtas is a corporate officer of North Star International Travel, Inc., rendering her dismissal an intra‑corporate controversy.
  • Whether the Court of Appeals correctly reversed the NLRC’s finding that Balagtas was a corporate officer and that the Labor Arbiter lacked jurisdiction.
  • Whether the appellate court’s awards of separation pay, backwages, damages, and attorney’...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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