G.R. No. 163782 - Light Rail Transit Authority vs. Venus Jr.

The Light Rail Transit Authority (LRTA) is a government-owned and controlled corporation established by Executive Order No. 603, Series of 1980, with an original charter. Its mandate is to construct, maintain, and operate a light rail transit system to provide efficient transportation.
Metro Transit Organization, Inc. (METRO), formerly known as Meralco Transit Organization, Inc., is a transportation corporation organized under the Corporation Code and registered with the Securities and Exchange Commission. It was later acquired by LRTA but retained its separate juridical personality.
In 1984, following a bidding process, LRTA entered into a ten-year Management and Operation Agreement with METRO for the light rail system running from Monumento in Kalookan City to Baclaran in Parañaque, Metro Manila.

LRTA commissioned METRO to take over the management, maintenance, and operation of the commissioned and tested portions of the light rail transit system upon commencement.
LRTA was to pay METRO a management fee, and METRO was required to exercise professional care, diligence, and efficiency.

METRO was authorized to hire its own personnel, and the employees so hired were to be considered employees of METRO.
METRO later entered into a collective bargaining agreement with its certified exclusive union, Pinag-isang Lakas ng Manggagawa sa METRO, Inc. (PIGLAS-METRO, Inc.), representing the rank-and-file workers.

On July 25, 2000, the union filed a Notice of Strike and initiated a strike, disrupting the light rail operations by shutting down substations and picketing across various terminals.
Due to the adverse impact on public transportation, Secretary of Labor Bienvenido E. Laguesma issued an assumption of jurisdiction order on the same day, directing the striking employees to return to work immediately under the previous terms and conditions.
Despite the issuance, posting, and publication of the order, the union’s officials and members, including the private respondent workers, did not comply.
As a result, starting July 27, 2000, the striking employees were considered dismissed by METRO.
Shortly after, on July 31, 2000, the management agreement between LRTA and METRO expired, and LRTA took over the operations to address the transportation crisis.

Private respondent workers (Perfecto H. Venus, Jr., Bienvenido P. Santos, Jr., Rafael C. Roy, Nancy C. Ramos, Salvador A. Alfon, Noel R. Santos, Manuel A. Ferrer, Salvador G. Alinas, Ramon D. Lofranco, Amador H. Policarpio, Reynaldo B. Gener, and Bienvenido G. Arpilleda) filed complaints for illegal dismissal before the National Labor Relations Commission (NLRC).
The Labor Arbiter initially ruled in favor of the complainants, ordering reinstatement without loss of seniority and awarding backwages, benefits, moral damages, and attorney’s fees.
On appeal, the NLRC reversed the Labor Arbiter’s decision, dismissing the case against LRTA on the ground that LRTA had no participation in terminating the workers’ employment.
Subsequent petitions for certiorari led the Court of Appeals to reinstate the Labor Arbiter’s decision by holding METRO liable for the illegal dismissal while dismissing the complaint against LRTA.
The case eventually reached the Supreme Court, which consolidated the petitions and addressed issues of employment relationship, jurisdiction, and the application of the doctrine of piercing the corporate veil.

Whether private respondent workers, hired by METRO under a separate collective bargaining agreement, could be considered employees of LRTA or solely of METRO.
Whether the workers are governed by the Labor Code (applicable to METRO) or by civil service rules (applicable to LRTA, a government-owned and controlled corporation with an original charter).

Whether the dismissal of the workers was justified on the grounds of job abandonment due to their failure to immediately return to work after the issuance of the return-to-work order.
Whether the immediate dismissal violated labor principles given the workers’ inability to return within the time frame provided, especially considering the operational shutdown of the light rail system.

Whether, despite METRO being acquired by LRTA, the separate corporate personality should be disregarded (i.e., piercing the corporate veil) to hold LRTA liable for the illegal dismissal of METRO’s employees.
Whether there was sufficient proof of wrongful, fraudulent, or unlawful acts justifying the imposition of joint liability upon LRTA.

Whether LRTA, as a government-owned and controlled corporation with an original charter, is under the jurisdiction of the Civil Service Commission and not the Department of Labor and Employment.
How the distinction between the employment status of METRO’s workers and LRTA’s employees affects the resolution of the claims.