Case Digest (G.R. No. 221813) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Maricalum Mining Corporation v. Florentino et al. (G.R. Nos. 221813 & 222723, July 23, 2018), the Philippine Government, through the Asset Privatization Trust (APT), sold 90% of Maricalum Mining Corporation’s shares and notes to G Holdings, Inc. under a Purchase and Sale Agreement dated October 2, 1992. The notes, converted into three promissory notes secured by mortgages on mining properties, obligated Maricalum to pay G Holdings. Upon partial payment, G Holdings took possession of Maricalum’s mining complex and assumed operational control. Between 1998 and 1999, several retired workers formed five manpower cooperatives. In 2000, each cooperative executed identical Memoranda of Agreement with Maricalum to supply labor and equipment for a monthly fee. On June 1, 2001, Maricalum announced it would cease mining operations. In July 2001, its mortgaged properties were foreclosed and sold to G Holdings as the highest bidder.On September 23, 2010, some former Maricalum workers
Case Digest (G.R. No. 221813) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ownership and Privatization
- The Philippine National Bank (PNB) and Development Bank of the Philippines (DBP) transferred ownership of Maricalum Mining Corporation (“Maricalum”) to the National Government’s Asset Privatization Trust (“APT”) as a non‐performing asset.
- On October 2, 1992, APT sold 90% of Maricalum’s shares and financial claims to “G” Holdings, Inc. (“G Holdings”) for ₱673,161,280, with G Holdings assuming three promissory notes of ₱550,000,000 secured by mortgages on Maricalum’s properties.
- Upon paying the down payment, G Holdings took possession and control of Maricalum’s Sipalay Mining Complex, facilities, and management.
- Manpower Cooperatives & Service Agreements
- From December 1998 to September 1999, retired Maricalum employees formed five labor cooperatives:
- San Jose Multi-Purpose Cooperative
- Centennial Multi-Purpose Cooperative
- Sipalay Integrated Multi-Purpose Cooperative
- Allied Services Multi-Purpose Cooperative
- Cansibit Multi-Purpose Cooperative
- In 2000, each cooperative executed identical Memoranda of Agreement with Maricalum to supply workers, machinery, and equipment for a monthly fee.
- Cessation of Operations & Foreclosure
- On June 1, 2001, Maricalum notified the cooperatives it would cease mining and milling operations effective July 1, 2001.
- In July 2001, mortgaged properties were extra-judicially foreclosed and sold to G Holdings as highest bidder on December 3, 2001.
- Labor Complaints & Procedural History
- September 23, 2010: Maricalum workers and Sipalay General Hospital employees filed Illegal Dismissal and monetary claims against G Holdings and the cooperatives before the Labor Arbiter (“LA”).
- The LA consolidated the complaints, held G Holdings, Maricalum, and the cooperatives jointly liable, and awarded unpaid wages, 13th-month pay, and attorney’s fees (April 28, 2011 Decision).
- July 18, 2011: Maricalum filed an Appeal-in-Intervention before the National Labor Relations Commission (“NLRC”).
- November 29, 2011 NLRC Decision: canceled awards to three employees; shifted liability from G Holdings to Maricalum for remaining awards; adjusted attorney’s fees.
- January 31, 2012 NLRC Resolution: canceled awards for two additional employees.
- October 29, 2014 Court of Appeals Decision: denied certiorari petitions; affirmed NLRC factual findings and awards in all respects.
Issues:
- Did the Court of Appeals err in refusing to re-evaluate factual findings and in finding no grave abuse of discretion by the NLRC?
- Did the CA err in affirming the NLRC’s substantial-evidence finding and in declining to remand to the LA for recomputation of monetary awards?
- Did the CA err in disregarding that Maricalum was allowed to intervene only on appeal?
- Did the CA err in upholding piercing of the corporate veil against Maricalum Mining but not against Sipalay General Hospital?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)