Case Digest (G.R. No. 90856)
Facts:
Arturo de Guzman v. National Labor Relations Commission (2nd Division), G.R. No. 90856, February 01, 1996, Special First Division, Francisco, J., writing for the Court.
Petitioner Arturo de Guzman was the general manager of the Manila office of Affiliated Machineries Agency, Ltd. (AMAL). In 1986 AMAL decided to cease operations; several former employees (private respondents) filed a complaint for illegal dismissal and non‑payment of statutory benefits against AMAL and impleaded petitioner on the allegation that he had sold part of AMAL’s assets, applied the proceeds and remaining assets to satisfy his own claims against the company, and formed Susarco, Inc. to continue the same line of business with AMAL’s former clients.
On September 30, 1987, the Labor Arbiter found petitioner jointly and severally liable with AMAL for the employees’ monetary claims. The National Labor Relations Commission affirmed the Labor Arbiter’s decision in toto on appeal. Petitioner then brought a petition for certiorari to the Supreme Court, asserting grave abuse of discretion.
By a decision promulgated July 23, 1992, the Court modified the NLRC ruling: it absolved petitioner from solidary liability with AMAL because, as a managerial employee, he did not participate in the decision to cease operations; but it found that petitioner acted in bad faith by appropriating AMAL’s assets to his own use to the prejudice of the employees and therefore ordered him to pay moral damages of P20,000, exemplary damages of P20,000, and to return the appropriated assets or their value with legal interest, to be distributed proportionately among the private respondents.
Petitioner moved for reconsideration of that July 23, 1992 decision, contending that in the absence of an employer‑employee relationship between him and the private respondents the Court lacked jurisdiction to award damages and order the return of AMAL’s assets in an illegal dismissal action. The special First Division (Francisco, J.) issued the present resolution denying the motion for reconsideration and affirming the earlier modification and remedies ordered by the Court.
Issues:
- In a complaint for illegal dismissal and non‑payment of statutory benefits, does the absence of an employer‑employee relationship between an impleaded third party (petitioner) and the complaining employees preclude the Court from awarding damages or ordering restitution against that third party?
- Were the awards of moral and exemplary damages and the order to return AMAL’s appropriated assets to petitioner proper under the facts and applicable law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)