Title
Chua vs. National Labor Relations Commission
Case
G.R. No. 89971-75
Decision Date
Oct 17, 1990
Stanford Microsystems, Inc. faced labor claims from thousands of employees during its rehabilitation and liquidation. The Supreme Court upheld a majority-backed Memorandum of Agreement, nullifying NLRC interference and affirming the validity of the settlement.
A

Case Digest (G.R. No. 89971-75)

Facts:

  • Parties, petition, and questioned NLRC actions
  • Petitioners Celia B. Chua, Marites P. Martinez, and Araceli A. Elardo, for themselves and as attorneys-in-fact of two thousand three hundred forty-five (2,345) former daily-paid employees of Stanford Microsystems, Inc., and other named petitioners similarly positioned, sued on behalf of additional groups of former Stanford employees, including a liquidation committee duly appointed by the Securities and Exchange Commission.
  • Respondents were the National Labor Relations Commission, the Labor Arbiter Dominador M. Cruz, and private respondents including Fernando R. Gumabon and others (collectively the private respondents).
  • Petitioners challenged the NLRC’s jurisdiction in issuing three (3) resolutions dated October 6, 1988, November 3, 1988, and January 3, 1990 in NLRC Injunction Case No. 1793.
  • The October 6, 1988 NLRC resolution denied petitioners’ petition for writ of prohibition to stay further proceedings in five (5) consolidated labor cases pending before Labor Arbiter Cruz.
  • The November 3, 1988 NLRC resolution ordered petitioner Liquidation Committee of Stanford Microsystems, Inc. to defer payment of P6,000,000.00 to the former employees of Stanford.
  • The January 3, 1990 resolution directed, among others, that the petitioners’ liquidation committee deposit with the NLRC the deducted attorney’s fees representing ten percent (10%) of the amount due and/or to be paid to former employees.
  • Stanford’s suspension of payments, rehabilitation receiver, and eventual liquidation
  • In December 1985, Stanford Microsystems, Inc. filed with the SEC a petition for suspension of payments and appointment of rehabilitation receiver, docketed as SEC Case No. 2930.
  • At that time, Stanford had seven (7) secured creditor banks and approximately seven thousand one hundred twenty-four (7,124) employees.
  • On February 5, 1986, the SEC declared Stanford in a state of suspension of payments, and appointed Sycip Gorres & Velayo & Co. (SGV) as rehabilitation receiver.
  • In January 1987, the SEC disapproved Stanford’s rehabilitation plan submitted by SGV and dismissed Stanford’s suspension of payments and rehabilitation receiver petition.
  • Subsequently, the SEC ordered Stanford’s liquidation.
  • Labor cases filed by former employees and later consolidation
  • After the SEC developments, the former employees filed money-claims cases with the Department of Labor and Employment (DOLE)/labor arbiters, as follows:
1) STOSEA-FFW and others (with petitioners Mario A. Mentil, Noel Villena, and Remigio F. Santos as attorneys-in-fact for five hundred ninety-nine (599) monthly-paid employees) against Stanford and Cristino Concepcion, Jr., assigned to Labor Arbiter Ceferina Diosana; the case had been decided, but execution was suspended at complainants’ instance. 2) Rodolfo Fernandez, et al. (with petitioners Rodolfo Fernandez, Maximo E. Daquil, George T. Bartolome, and Ernesto L. Concepcion as attorneys-in-fact for three hundred (300) confidential and non-unionized employees) assigned to Labor Arbiter Raymundo R. Valenzuela; the case was archived at complainants’ instance. 3) Stanford Microsystems, Inc. Labor Union-FFW (with petitioners Celia B. Chua, Araceli A. Elardo, and Marites P. Martinez as attorneys-in-fact for two thousand three hundred forty-five (2,345) daily-paid employees) assigned to Labor Arbiter Benigno C. Villarente then to Labor Arbiter Alex Arcadio Lopez; the case had been decided, but execution was suspended and the case archived at complainants’ instance. 4) Ludivina L. Sabalza, Adeliza E. Cantillo, Remigio P. Pestano, et al. (with petitioners as attorneys-in-fact for three thousand two hundred forty-four (3,244) daily-paid employees) assigned to Labor Arbiter Evangeline Lubaton; the petitioners’ liquidation committee intervened and moved to stay proceedings. 5) SMI Labor Union-FFW, et al. (with petitioners as attorneys-in-fact for three thousand two hundred forty-four (3,244) daily-paid employees) assigned to Labor Arbiter Dominador M. Cruz; the liquidation committee intervened and moved to stay proceedings. 6) Ludivina Sabalza, et al. (with petitioners as attorneys-in-fact for three thousand two hundred forty-four (3,244) daily-paid employees) assigned to Labor Arbiter Dominador M. Cruz; the liquidation committee intervened and moved to stay proceedings. 7) Ludivina Sabalza, et al. with Fernando R. Gumabon, et al. (with petitioners as attorneys-in-fact for three thousand two hundred forty-four (3,244) daily-paid employees) assigned earlier to Labor Arbiter Armando Polintan; the liquidation committee intervened and moved to stay proceedings. 8) Fernando R. Gumabon, et al. (with petitioners Mario A. Mentil, Noel Villena, and Remigio F. Santos as attorneys-in-fact for five hundred ninety-nine (599) monthly-paid employees) assigned earlier to Labor Arbiter Martinez; the liquidation committee intervened and moved to stay proceedings.
  • Except for cases (a), (b), and (c) (assigned to different labor arbiters), cases (d) to (h) were consolidated and assigned to Labor Arbiter Cruz.
  • Petitioners in cases (d) to (h) involved former daily-paid employees who were members of the Stanford Microsystems, Inc., Labor Union (SMILU).
  • Caretaker Committee, attorneys-in-fact, and engagement of counsel
  • The former daily-paid employees formed a “Caretaker Committee.”
  • The Caretaker Committee appointed Ludivina L. Sabalza, Adeliza E. Cantillo, and Remigio P. Pestano as attorneys-in-fact to prosecute and settle claims against Stanford before both the SEC and the DOLE.
  • These attorneys-in-fact engaged private respondent Atty. Vicente Ocampo as legal counsel.
  • Termination of Atty. Ocampo and class suit before the SEC
  • On their behalf, Atty. Ocampo’s services were terminated as early as October and November 1986 due to refusal to represent the group in negotiations with other Stanford employees and the creditors toward an out-of-court settlement.
  • A termination letter dated March 9, 1987 was received by Atty. Ocampo on March 11, 1987.
  • The termination letter stated that the employees accepted Atty. Ocampo’s decision not to represent them in negotiations, and that they had to engage another counsel for the case then pending before the Ministry of Labor, the SEC, and other tribunals including negotiations for settlement.
  • On October 2, 1987, the SEC en banc issued an order appointing the same eleven (11) members of the MOA Liquidation Committee as the permanent SEC Liquidator of Stanford pursuant to Presidential Decree No. 902-A, as amended.
  • Atty. Ocampo claimed he remained counsel for the group represented by Ludivina L. Sabalza, Adeliza E. Cantillo, and Remigio P. Pestano, and filed a “class suit” for reconsideration of the SEC order.
  • During an SEC en banc hearing on December 17, 1987, the SEC directed the Stanford Liquidation Committee and Atty. Ocampo to submit the number and names of former Stanford employees represented by them.
  • On January 22, 1988, the Stanford Liquidation Committee filed compliance, including copies of special powers of attorney, the list of names of the 6,341 former employees who executed special powers of attorney, and letters-certifications that the employees executed the special powers of attorney in favor of the workers representatives.
  • Atty. Ocampo failed to comply with the directive.
  • On October 12, 1988, the SEC en banc denied Atty. Ocampo’s motion...(Subscriber-Only)

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