Case Digest (G.R. No. 163782)
Facts:
Light Rail Transit Authority v. Perfecto H. Venus, Jr., G.R. Nos. 163782 and 163881, March 24, 2006, Supreme Court Second Division, Puno, J., writing for the Court. Petitioners are the Light Rail Transit Authority (LRTA) and Metro Transit Organization, Inc. (METRO); respondents are a group of former METRO rank-and-file employees who challenged their dismissal (hereafter, the private respondent workers).The LRTA was created by Executive Order No. 603, Series of 1980 to construct and maintain the Light Rail Transit System. In 1984 LRTA contracted with METRO under a ten-year Agreement for the Management and Operation of the Metro Manila Light Rail Transit System (June 8, 1984–June 8, 1994), under which METRO would manage, operate and hire its own personnel and hold LRTA harmless for most liabilities. METRO employed the private respondent workers and, in 1995, METRO entered into a collective bargaining agreement with PIGLAS‑METRO, INC., the certified union.
On June 9, 1989, LRTA purchased METRO’s shares, but both entities continued to maintain separate juridical personalities; the management agreement was extended after its 1994 expiration, initially yearly then monthly. On July 25, 2000 the union notified a strike and picketing began; power supply switches at substations were turned off, paralyzing the system. That same day, Secretary of Labor Bienvenido E. Laguesma issued an assumption of jurisdiction and return‑to‑work order directing the strikers to resume work immediately. DOLE sheriffs attempted personal service on July 26, 2000; when refused, they posted the order at stations and published it in the Philippine Daily Inquirer and the Philippine Star on July 27, 2000.
Despite posting and publication, the striking union members, including the private respondent workers, did not return; METRO considered them dismissed effective July 27, 2000. On July 31, 2000 LRTA elected not to renew METRO’s contract and took over operations. The workers filed illegal dismissal complaints: Venus, Santos and Roy on October 10, 2000; the other respondents on December 1, 2000. Labor Arbiter Luis D. Flores (October 1, 2001) ruled for the complainants, ordering reinstatement without loss of seniority, payment of full back wages and benefits, moral damages of P50,000 each, and attorney’s fees of 10% of the money judgment.
On appeal the National Labor Relations Commission (NLRC) (First Division) reversed on May 29, 2002, finding that the strikers failed to heed the return‑to‑work order and dismissing the case against LRTA for lack of participation and against METRO for lack of merit; the NLRC denied reconsideration on December...(Subscriber-Only)
Issues:
- Whether the corporate veil of Metro Transit Organization, Inc. may be pierced to hold Light Rail Transit Authority liable as employer of METRO’s workers.
- Whether the private respondent workers were legally dismissed or had abandoned their employment by failing to comply with the Secretary of Lab...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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