Case Digest (G.R. No. 157802)
Facts:
The petition involved Matling Industrial and Commercial Corporation, Richard K. Spencer, Catherine Spencer, and Alex M. Mancilla (Petitioners) and Ricardo R. Coros (Respondent) after Coros filed on August 10, 2000 with the National Labor Relations Commission (Sub-Regional Arbitration Branch XII, Iligan City) a complaint for illegal suspension and illegal dismissal following his termination as Vice President for Finance and Administration.
The Labor Arbiter dismissed the complaint on October 16, 2000 as an intra-corporate matter under Presidential Decree No. 902; the NLRC set aside that dismissal on March 13, 2001 and remanded the case to the Arbiter; the Court of Appeals affirmed the NLRC on September 13, 2002, and the petitioners brought the case to the Supreme Court.
Issues:
- Was Ricardo R. Coros a corporate officer of Matling Industrial and Commercial Corporation?
- If he was a corporate officer, did the dismissal constitute an intra-corporate dispute within the exclusive jurisdiction of the Securities and Exchange Commission (now the Regional Trial Court under Republic Act No. 8799) rather than a labor termination matter cognizable by the Labor Arbiter?
Ruling:
The petition for review was denied and the Court affirmed the decision of the Court of Appeals. The Court held that Coros was not a corporate officer but an ordinary employee promoted through the ranks and appointed Vice President by the corporation's President, and therefore his complaint for illegal dismissal was within the jurisdiction of the Labor Arbiter under Article 217(a)(2) of the Labor Code. Costs were imposed on the petitioners.
Ratio:
The Court applied Section 25, Corporation Code, which confines corporate officers to those designated by the Code or expressly provided for in the corporation's By-Laws, and reasoned that an enabling clause authorizing the President to create offices did not convert such appointees into corporate officers. The power to elect corporate officers rested with the Board of Directors and could not be validly delegated to the President. Coros's appointment resulted from his long service and executive selection by the President, not from election by the Board or stockholders, and his status as stockholder/director did not, without more, render his dismissal an intra-corporate controversy. While Republic Act No. 8799 transferred intra-corporate jurisdiction from the SEC to the RTC, that transfer did not apply because the position in question was not a corporate office within the meaning of Section 25.
Doctrine:
- Article 217(a)(2) of the Labor Code vests the Labor Arbiter with original and exclusive jurisdiction over termination disputes.
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