Case Digest (G.R. No. 113907)
Facts:
Malayang Samahan ng mga Manggagawa sa M. Greenfield (MSMG‑UWP) et al. v. Hon. Cresencio J. Ramos, National Labor Relations Commission, M. Greenfield (B), Inc., et al., G.R. No. 113907, April 20, 2001, Supreme Court Third Division, Gonzaga‑Reyes, J., writing for the Court.Petitioners are hundreds of former employees and union officers of M. Greenfield (B), Inc. (collectively, petitioners). Respondents include the NLRC, the company, and several corporate officers (Saul Tawil, Carlos T. Javelosa, Renato C. Puangco, among others). The underlying dispute concerned the summary dismissal of petitioners and their entitlements (reinstatement, separation pay or backwages).
Chronology: petitioners filed a complaint with the Department of Labor and Employment (DOLE) on September 6, 1989, challenging their dismissal. The case proceeded to the National Labor Relations Commission, which rendered a decision (Case No. NCR‑00‑09‑04199‑89) adverse to petitioners. The petitioners sought relief from the Supreme Court; in a decision dated February 28, 2000 the Court granted the petition, reversed the NLRC and ordered reinstatement (or separation pay) and backwages. Thereafter petitioners filed a motion for partial reconsideration of that Supreme Court decision.
In their motion petitioners alleged patent and palpable error in the Court’s refusal to hold certain corporate officers personally liable; they also presented facts they claimed showed the company was dismantling operations and diverting work to several “satellite” garment companies allegedly linked to the same officers. Separately, petitioners moved to include and to correct the names of employees inadvertently omitted from the caption and Annex “D.” The Solicitor General did not object to the inclusion/correction of names. Private respondent officers opposed admission of the newly‑tendered evidence as untimely and objected to inclusion of non‑parties. The company itself failed to file a comment and could not be served at one point.
The present resolution resolves petitioners’ motion for partial reconsideration: i...(Subscriber-Only)
Issues:
- May corporate officers of M. Greenfield (B), Inc. be held personally liable for the dismissal of petitioners and payment of backwages and other money claims?
- Should the Court allow petitioners to include in the caption employees listed in Annex “D” who were inadvertently omitted and to correct typographical errors in employee names already in the caption?
- May petitioners, at this late stage, be permitted to include additional employees who were not parties to the act...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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