G.R. No. L-11466 - Luis G. Ablaza vs. Gabriel A. Ignacio

Virgilio S. Delima (petitioner) filed a case for illegal dismissal against Golden Union Aquamarine Corporation (Golden), Prospero Gois, and Susan Mercaida Gois (respondent) before the Regional Arbitration Branch No. VIII of the National Labor Relations Commission (NLRC) on October 29, 2004 (NLRC RAB VIII Case No. 10-0231-04).
On April 29, 2005, Labor Arbiter Philip B. Montaces rendered a decision finding the dismissal illegal and ordering Golden to pay Delima backwages, separation pay, salary differentials, service incentive leave pay, and attorney’s fees, totaling ₱115,561.05.
Golden did not appeal, thus the decision became final and executory. A writ of execution was issued and an Isuzu Jeep (plate no. PGE-531) was attached.

Susan Mercaida Gois claimed the attachment was irregular as the vehicle was registered to her and she was not a party to the illegal dismissal case.
The Labor Arbiter denied her third-party claim on December 29, 2005, noting she was named a respondent in the complaint and was an officer/incorporator of Golden.
Gois filed an appeal with the NLRC and moved for the release of the vehicle after substituting it with a cash bond of ₱115,561.05.
On January 16, 2006, the Labor Arbiter granted the motion and ordered release of the vehicle upon substitution with the cash bond.

NLRC dismissed Gois’s appeal on May 31, 2006, and denied her motion for reconsideration on August 22, 2006; the resolution became final on September 12, 2006.
An Entry of Judgment was issued on September 29, 2006.
Gois filed a petition for certiorari with the Court of Appeals (CA) on October 13, 2006, alleging grave abuse of discretion by the NLRC for dismissing her appeal and argued that as a stockholder and not the president or majority owner, she was not personally liable for the corporation’s obligation.

The CA annulled and set aside the NLRC resolutions of May 31 and August 22, 2006.
CA held that the company alone was liable, not Gois personally, because the corporation has a separate legal personality.
It further held that without evidence of malice or bad faith, corporate officers cannot be held solidarily liable for illegal dismissal damages.
CA ordered return of the cash bond to Gois.

Petitioner Delima assailed the CA ruling raising issues on the omission of respondent as principal respondent, the ownership and garnishment of the vehicle, and the annulment of final NLRC resolutions.
Supreme Court took up the case for review.

Whether the Court of Appeals erred in omitting Susan Gois as one of the principal respondents in the original complaint.
Whether the vehicle, registered under Susan Gois’s name but principally used in the corporation’s business, can be subject to garnishment to satisfy the judgment against the corporation.
Whether the Court of Appeals erred in annulling and setting aside a final and executory order/resolution of the NLRC.