Case Digest (G.R. No. 157802) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Matling Industrial and Commercial Corporation, et al. v. Ricardo R. Coros, G.R. No. 157802, decided October 13, 2010, the respondent, Ricardo R. Coros, was dismissed by Matling Industrial and Commercial Corporation from his position as Vice President for Finance and Administration on April 17, 2000. On August 10, 2000, he filed a complaint for illegal suspension and illegal dismissal before the National Labor Relations Commission (NLRC), arguing that he was a regular employee. The petitioners moved to dismiss for lack of jurisdiction, asserting that Coros was a member of Matling’s Board of Directors and thus a corporate officer, making his dismissal an intra-corporate dispute under the exclusive jurisdiction of the Securities and Exchange Commission (SEC), now the Regional Trial Court (RTC), pursuant to Section 5, paragraph (c) of Presidential Decree No. 902 and Section 5.2 of Republic Act No. 8799. The Labor Arbiter granted the motion to dismiss, declaring Coros a corporate Case Digest (G.R. No. 157802) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- Ricardo R. Coros, Vice President for Finance and Administration of Matling Industrial and Commercial Corporation (Matling), was dismissed on April 17, 2000.
- On August 10, 2000, Coros filed a complaint for illegal suspension and illegal dismissal with the NLRC (Sub-Regional Arbitration Branch XII, Iligan City).
- Matling and its officers moved to dismiss for lack of jurisdiction, arguing Coros was a corporate officer (member of the Board of Directors) and that his removal was an intra-corporate matter under SEC jurisdiction.
- Coros opposed, contending he was not formally elected director, owned no stock, and his removal was as VP, not as director.
- Proceedings below
- Labor Arbiter (LA) (October 16, 2000) granted the motion to dismiss, ruling Coros a corporate officer and the dispute an intra-corporate matter under PD 902.
- NLRC (March 13, 2001) set aside the dismissal, holding the LA had jurisdiction because the VP for Finance and Administration was not among the corporate offices listed in Matling’s By-Laws.
- NLRC denied reconsideration (April 30, 2001) despite submission of Matling’s Amended Articles and minutes.
- Court of Appeals (CA) (September 13, 2002) dismissed petition for certiorari, affirming NLRC: Coros’s position was an ordinary office, not a corporate office, hence cognizable by the LA.
- CA denied reconsideration (April 2, 2003).
Issues:
- Jurisdictional issue before the Supreme Court
- Was Coros a “corporate officer” of Matling whose dismissal is an intra-corporate dispute under SEC/RTC jurisdiction?
- Or was he a regular employee with a non-corporate office, making his illegal dismissal cognizable by the Labor Arbiter?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)