Case Digest (G.R. No. 90856)
Facts:
Arturo de Guzman v. National Labor Relations Commission, G.R. No. 90856, July 23, 1992, the Supreme Court First Division, Cruz, J., writing for the Court. Arturo de Guzman (petitioner) was the general manager of the Manila office of Affiliated Machineries Agency, Ltd. (AMAL), a Hong Kong–based company. On June 30, 1986, he received a telex from Leo A. Fialla, AMAL’s managing director, advising of the company’s closure for financial reasons. De Guzman informed the Manila personnel, who accepted the closure only on condition of payment of salaries, separation pay and other statutory benefits; De Guzman joined those representations but the company did not pay.When their demands were not honored, the employees (the private respondents) filed a complaint with the NLRC against AMAL, Leo Fialla and De Guzman for illegal dismissal and various unpaid benefits. De Guzman proceeded to appropriate and sell AMAL property in the Philippines and applied the proceeds to his own claims; he also organized Susarco, Inc. (with himself as president and his wife as incorporator), which engaged in the same business. Susarco and certain officers were impleaded but later dismissed from the employees’ NLRC petition.
On November 7, 1986 De Guzman filed his own NLRC complaint against AMAL. On May 29, 1987 Labor Arbiter Eduardo Magno ordered AMAL to pay De Guzman P371,469.59 after deducting the value of assets De Guzman had appropriated. On September 30, 1987 Labor Arbiter Ma. Lourdes A. Sales rendered a decision ordering AMAL and Arturo de Guzman jointly and severally to pay each complainant separation pay (one-half month per year), one month backwages, unpaid June 16–30, 1986 salary, 13th month pay for January–June 1986, and incentive leave pay; the Arbiter dismissed claims against other impleaded parties and awarde...(Pro-only)
Issues:
- Did the NLRC act without or in excess of jurisdiction in holding petitioner jointly and severally liable with AMAL?
- Was petitioner personally liable to the private respondents for appropriating AMAL’s assets in bad faith and thus subject to award of moral and exemplary damages?
- Did the Labor Arbiter and the NLRC have jurisdiction to adjudicate and award moral and exemplary damages arising from the labor dispute, or must such da...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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