Case Digest (G.R. No. 96149)
Facts:
- Conchita S. Hautea, the widow of Jose H. Hautea, aimed to nullify an NLRC decision dated August 13, 1990.
- The NLRC annulled a Labor Arbiter's ruling from March 12, 1987, which mandated Calinog-Lambunao Sugar Mill, Inc. (CLSMI) to pay Jose H. Hautea P276,000 in separation pay, retirement benefits, moral damages, and attorney's fees.
- The annulment was based on improper service of summons to the Philippine National Bank (PNB), a party-respondent.
- The NLRC contended that PNB could not be held liable due to inadequate notification and that execution against PNB's foreclosed properties was not allowed.
- Jose Hautea had been employed by CLSMI since January 1967 and retired in December 1984.
- PNB foreclosed CLSMI's properties on December 2, 1986.
- After his retirement, Jose Hautea filed a complaint against CLSMI and PNB on January 12, 1987.
- The Labor Arbiter ruled in favor of Hautea, but CLSMI and PNB did not attend the hearings, resulting in their default.
- Following Jose Hautea's death on July 31, 1987, Conchita Hautea became the petitioner.
- The NLRC's decision lifted the levy on PNB's properties and set aside the Labor Arbiter's ruling.
Issue:
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Ruling:
- The Supreme Court upheld the NLRC's decision.
- The Court determined that the service of summons to PNB was improper, relieving PNB of liability for Jose H. Hautea's claims.
- The Court ruled that Section 27 of Proclamation No. 50 did not apply to...(Unlock)
Ratio:
- Proper service of summons is essential for a court to establish jurisdiction over a party.
- As PNB was not properly served, it could not be held liable for Hautea's claims.
- The Labor Arbiter's decision was conclusive regarding CLSMI's obligations but did not extend to PNB, which was not th...continue reading
Case Digest (G.R. No. 96149)
Facts:
The case of Hautea v. National Labor Relations Commission involves Conchita S. Hautea, the widow of Jose H. Hautea, who sought to nullify a decision rendered by the National Labor Relations Commission (NLRC) on August 13, 1990. This decision annulled a prior ruling made by a Labor Arbiter on March 12, 1987, which mandated Calinog-Lambunao Sugar Mill, Inc. (CLSMI) to pay Jose H. Hautea a total of P276,000, encompassing separation pay, retirement benefits, moral damages, and attorney's fees. The NLRC's annulment was predicated on the assertion that summons had not been properly served to the Philippine National Bank (PNB), a party-respondent in the case. The NLRC contended that since PNB had not been adequately notified, it could not be held liable for the claims made by Hautea. Additionally, the NLRC noted that execution against properties foreclosed by PNB could not be maintained. Jose Hautea had been employed by CLSMI since January 1967 and retired in December 1984. Following his retirement, CLSMI's properties were foreclosed by PNB on December 2, 1986. On January 12, 1987, Jose Hautea filed a complaint against CLSMI and PNB for separation pay and other benefits. The Labor Arbiter ruled in favor of Hautea, but both CLSMI and PNB failed to appear during the hearings, resulting in their default. After Jose Hautea's death on July 31, 1987, Conchita Hautea substituted him as the petitioner. The NLRC's decisi...