Case Digest (G.R. No. 108734) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Concept Builders, Inc. vs. National Labor Relations Commission, petitioner Concept Builders, Inc. (CBI), a domestic construction corporation with principal office at 355 Maysan Road, Valenzuela, Metro Manila, terminated the employment of private respondents—laborers, carpenters, and riggers—on November 30, 1981, ostensibly because their project was finished. Contrary findings by the Labor Arbiter and the NLRC showed that the project remained incomplete and CBI had hired subcontractors to perform the same work. Private respondents successfully sued for illegal dismissal and non-payment of benefits, obtaining a December 19, 1984 decision reinstating them and awarding backwages. After partial satisfaction through garnishment, an alias writ was issued on February 1, 1989 for the remaining balance and reinstatement. The sheriff’s efforts to levy on CBI property at 355 Maysan Road were frustrated by claims from Hydro Pipes Philippines, Inc. (HPPI), a sister corporation sharing the Case Digest (G.R. No. 108734) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment, termination and labor proceedings
- Petitioner Concept Builders, Inc., a domestic construction corporation with principal office at 355 Maysan Road, Valenzuela, Metro Manila, employed private respondents as laborers, carpenters, and riggers.
- In November 1981, respondents received notices of termination effective November 30, 1981, on the ground that their project had been completed, although it was not; petitioner thereafter engaged subcontractors to perform their work.
- Judicial and enforcement processes
- December 19, 1984: The Labor Arbiter ordered petitioner to reinstate respondents and pay back wages equivalent to 300 days.
- November 27, 1985: The NLRC denied petitioner’s motion for reconsideration; the decision became final.
- October 29, 1986: Writ of execution issued; garnishment of P81,385.34 from Metropolitan Waterworks and Sewerage Authority.
- February 1, 1989: Alias writ for P117,414.76 and reinstatement issued; service refused because petitioner vacated premises.
- September 26, 1989: Second alias writ issued; sheriff’s November 2, 1989 report noted employees claimed affiliation with Hydro Pipes Philippines, Inc. (HPPI), levy made on personal properties, and security guards barred removal—recommended break-open order.
- Third-party claim and break-open order proceedings
- November 6, 1989: Dennis Cuyegkeng filed a third-party claim asserting HPPI ownership of the levied properties.
- November 23, 1989: Private respondents moved for a break-open order, alleging HPPI and petitioner shared incorporators, stockholders, officers, and premises; offered an indemnity bond. They submitted General Information Sheets (GIS) of both corporations showing identical directors, officers, and the same office address.
- February 1, 1990: HPPI opposed, claiming a separate manufacturing business.
- March 2, 1990: Labor Arbiter denied the break-open order.
- April 23, 1992: NLRC set aside the arbiter’s order, issued the break-open order, directed auction of levied properties, and dismissed HPPI’s third-party claim.
- December 3, 1992: NLRC denied petitioner’s motion for reconsideration.
Issues:
- Procedural Issue
- Whether the NLRC committed grave abuse of discretion by issuing a break-open order and ordering execution despite HPPI’s third-party claim on the levied properties.
- Substantive Issue
- Whether the corporate veil of HPPI should have been pierced—treating HPPI as alter ego of petitioner—to subject its assets to execution, notwithstanding differences in declared business activities.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)