G.R. No. 198967 - Guillermo vs. Uson

Crisanto P. Uson was employed by Royal Class Venture Phils., Inc. (Royal Class Venture) starting March 11, 1996, as an accounting clerk, later promoted to accounting supervisor with a monthly salary of Php13,000.00.
Uson was allegedly dismissed from employment on December 20, 2000.

On March 2, 2001, Uson filed a Complaint for Illegal Dismissal with the National Labor Relations Commission (NLRC), praying for backwages, reinstatement, 13th month pay, moral and exemplary damages, and attorney’s fees against Royal Class Venture.
Royal Class Venture failed to appear despite summons.
Uson filed his Position Paper on May 15, 2001.
Labor Arbiter Jose G. De Vera rendered a Decision on October 22, 2001, in favor of Uson, ordering Royal Class Venture to reinstate Uson and pay his claims including damages and attorney’s fees.
Royal Class Venture did not appeal the decision.

A Writ of Execution was issued on February 15, 2002, followed by Alias Writs on May 17 and September 11, 2002, all reported unsatisfied.
On November 14, 2002, Uson filed a Motion for Alias Writ of Execution and to Hold Directors and Officers Personally Liable for satisfaction of the decision.
The Sheriff’s return indicated that at Royal Class Venture’s address was a different company, Joel and Sons Corporation, a family corporation owned by the Guillermos, with petitioner Jose Emmanuel F. Guillermo, the General Manager and stockholder of Royal Class Venture, receiving the writ under a false identity (“Joey”). It was also mentioned that Royal Class Venture was dissolved.

On December 26, 2002, Labor Arbiter Irenarco R. Rimando granted Uson’s motion, piercing the corporate veil and holding Guillermo personally and solidarily liable as an officer for the obligations of Royal Class Venture.
Guillermo filed a Motion for Reconsideration which was denied on November 24, 2003, with Labor Arbiter NiAa Fe S. Lazaga-Rafols censuring Guillermo for unexplained absence despite notice.
Guillermo’s motion for reconsideration filed on January 5, 2004, was denied on January 7, 2004.

Uson filed several motions for Alias Writs of Execution; Guillermo opposed these, but the Labor Arbiter ruled in favor of Uson.
Guillermo appealed to the NLRC, which dismissed his appeal on May 11, 2010, and denied his prayer for injunction.
Guillermo filed a petition for certiorari before the Court of Appeals, which on June 8, 2011, affirmed the NLRC decision.
The Court of Appeals found that summons was properly served on Guillermo as President and General Manager and that Guillermo unlawfully refused to receive notices and orders.
The Court of Appeals held that although the initial decision had become final and executory, it may be modified when execution becomes impossible or unjust, thus justifying the piercing of corporate fiction to hold Guillermo liable.
Guillermo’s Motion for Reconsideration was denied by the Court of Appeals on October 7, 2011.

Guillermo asserted that he was improperly impleaded only after the judgment became final and executory, arguing this violated rules of law and jurisprudence.
He claimed the lifting of the corporate veil was discriminatory and that the Labor Arbiter had no jurisdiction because the case involved an intra-corporate controversy, Uson also being a stockholder and director.
Uson’s Comment merely reproduced appellate decisions without introducing new arguments.

Whether an officer of a corporation may be impleaded as a judgment obligor in a labor case for the first time after a Labor Arbiter’s decision has become final and executory.

Whether the doctrines of piercing the veil of corporate fiction and personal liability of corporate officers apply under the facts presented.

Whether the labor case involves an intra-corporate controversy, thereby depriving the Labor Arbiter of jurisdiction.