Title
Maricalum Mining Corp. vs. Florentino
Case
G.R. No. 221813
Decision Date
Jul 23, 2018
Labor dispute over illegal dismissal and benefits; SC upheld separate corporate identities, dismissed claims against G Holdings, citing no fraud or control over Maricalum Mining.

Case Digest (G.R. No. 221813)
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)

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