Case Digest (G.R. No. 112661)
Facts:
- A group of petitioners, including Simeon De Leon and 116 others, filed a complaint against the National Labor Relations Commission (NLRC), Fortune Tobacco Corporation (FTC), and Magnum Integrated Services, Inc. (formerly Fortune Integrated Services, Inc. or FISI).
- The complaint involved allegations of illegal dismissal, unfair labor practices, and a request for the refund of a cash bond.
- FTC and FISI entered into a contract for security services on August 23, 1980, with FISI providing security guards for FTC's facilities.
- FISI changed ownership and was renamed Magnum Integrated Services, Inc. (MISI) on February 1, 1991.
- FTC terminated its contract with MISI on October 15, 1991, displacing approximately 582 security guards, including the petitioners.
- The Fortune Tobacco Labor Union sent a Notice of Strike to MISI, but a Regional Trial Court issued an injunction against the picket.
- The petitioners filed their complaint with the NLRC on November 29, 1991, alleging illegal dismissal and unfair labor practices.
- The Labor Arbiter initially ruled in favor of the petitioners, finding FTC and FISI to be a single employer.
- The NLRC later reversed this decision, claiming no employer-employee relationship existed between FTC and the petitioners.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the petitioners were illegally dismissed from their employment.
- The Court found the respondents guilty of unfair labor practices....(Unlock)
Ratio:
- The Supreme Court determined that the NLRC erred in concluding there was no employer-employee relationship between FTC and the petitioners.
- The Court applied the "piercing the corporate veil" doctrine, finding that FISI was merely an instrumentality of FTC due to shared stockholders, a common business address, and FISI having no clients other than FTC and its affiliates.
- The termination of the security services contract was viewed as a strategic move to undermine the newly formed union, constituting an unfair labor practice under Article 248 of the La...continue reading
Case Digest (G.R. No. 112661)
Facts:
This case involves a group of petitioners, including Simeon De Leon and 116 others, who filed a complaint against the National Labor Relations Commission (NLRC), Fortune Tobacco Corporation (FTC), and Magnum Integrated Services, Inc. (formerly Fortune Integrated Services, Inc. or FISI) for illegal dismissal, unfair labor practice, and the refund of a cash bond. The events leading to the case began on August 23, 1980, when FTC and FISI entered into a contract for security services, wherein FISI was tasked with providing security guards, including the petitioners, for FTC's facilities. On February 1, 1991, FISI underwent a change in ownership and was renamed Magnum Integrated Services, Inc. (MISI). Subsequently, on October 15, 1991, FTC terminated its contract with MISI, resulting in the displacement of approximately 582 security guards, including the petitioners. Following this termination, the Fortune Tobacco Labor Union, claiming to represent the security guards, sent a Notice of Strike to MISI. However, a Regional Trial Court issued an injunction against the picket organized by the union. On November 29, 1991, the petitioners filed their complaint with the NLRC, alleging illegal dismissal and unfair labor practices. The Labor Arbiter initially ruled in favor of the petitioners, finding FTC and FISI to be a single employer and h...