Facts:

The case involves a petition for review on certiorari filed by Norma D. Cacho and North Star International Travel, Inc. against Virginia D. Balagtas. The events leading to the case began when Balagtas, a former employee and one of the original incorporators of North Star, filed a complaint for constructive dismissal against the petitioners. Balagtas had served the corporation for 14 years, initially as General Manager and later as Executive Vice President/Chief Executive Officer. On March 19, 2004, she was placed under a 30-day preventive suspension due to alleged questionable transactions. Following her suspension, Balagtas attempted to resume her position but was prevented from doing so. Consequently, she filed a complaint claiming illegal dismissal effective April 12, 2004.

In their defense, the petitioners argued that Balagtas was not dismissed but merely suspended, and that her complaint was an intra-corporate controversy, which should fall under the jurisdiction of t...

Facts:

Employment Background and Appointment

• Respondent Virginia D. Balagtas initially presented herself as a former employee of TQ3 Travel Solutions/North Star International Travel, Inc.
• She alleged that she was one of the original incorporators and directors of the corporation, having served in key managerial capacities—from General Manager at the start of operations in 1990 to later becoming the Executive Vice President/Chief Executive Officer.

Suspension and Acts Leading to the Complaint

• On or about March 19, 2004, following 14 years of service, Balagtas was placed under a 30-day preventive suspension by a Board Resolution, purportedly due to questionable transactions and documents.
• She was notified by petitioner Norma D. Cacho, who acted in her capacity as President of North Star, and was ordered to explain, in writing, the alleged fraudulent transactions within five days of the notice.
• On March 29, 2004, Balagtas complied with the order by submitting the required explanation.
• Despite the submission, on April 5, 2004, while still under suspension, she attempted to resume her duties by sending a letter claiming her re-assumption of the Executive Vice President position, which was subsequently denied.
• A follow-up letter dated April 12, 2004, inquiring about the examination of the company’s financial records, went unanswered, leading her to file a complaint for constructive dismissal.

Respondents’ Defense and Counter-Allegations

• Petitioners Norma D. Cacho and North Star International Travel, Inc. argued that the suspension was a preventive measure aimed at safeguarding the company’s interests during an investigation into alleged unauthorized transactions.
• They contended that Balagtas did not suffer an outright dismissal but was temporarily suspended pending further inquiry.
• In their defense, they also asserted that Balagtas’s position, as later maintained, was that of a corporate officer, making the issue an intra-corporate controversy and subject to the jurisdiction of the Regional Trial Court rather than the Labor Arbiter.

Procedural History and Judicial Determinations

• The Labor Arbiter, in a decision dated March 28, 2005, ruled that Balagtas had been illegally dismissed and awarded separation pay, backwages, commissions, moral damages, exemplary damages, and attorney’s fees.
• Petitioners appealed the decision to the National Labor Relations Commission (NLRC), arguing lack of jurisdiction by emphasizing that, as a corporate officer, Balagtas’s case was an intra-corporate controversy.
• The NLRC, through its Resolution dated September 30, 2008, reversed the Labor Arbiter’s decision on the ground of lack of jurisdiction, ruling that a corporate officer’s dismissal should be handled by the courts.
• The Court of Appeals later granted Balagtas’s petition, reversing the NLRC’s resolution and affirming the Labor Arbiter’s decision by remanding the case for proper computation of benefits, while addressing the jurisdictional issue through a two-tier test.

Issue:

Whether respondent Balagtas qualifies as a corporate officer under the Corporation Code, case law, and North Star’s by-laws, thereby establishing an intra-corporate relationship.

• Is the Executive Vice President title, as held by Balagtas, encompassed within the vice-president positions provided in North Star’s by-laws?
• Does the manner of her appointment, as evidenced by the Secretary’s Certificate, validate her status as a corporate officer?

• Whether the appellate decision reversing the NLRC’s finding of lack of jurisdiction was correct, especially given the absence of a detailed discussion on the corporate officer issue in that decision.

• Whether the award of separation pay, backwages, moral damages, exemplary damages, and attorney’s fees to Balagtas by the appellate court was appropriate under the circumstances.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)