Case Digest (G.R. No. 216492)
Facts:
The case centers around John F. McLeod (the petitioner), who filed a complaint for various benefits against Filipinas Synthetic Fiber Corporation (Filsyn), Far Eastern Textile Mills, Inc. (FETMI), Sta. Rosa Textiles, Inc. (SRTI), Patricio L. Lim, and Eric Hu (the respondents). The complaint initiated on February 2, 1995, stemmed from McLeod's claims for retirement benefits, vacation and sick leave benefits, unused airline ticket payments, holiday pay, underpayment of salary, and 13th month pay, alongside moral and exemplary damages, and attorney's fees.
McLeod asserted his expertise in textile manufacturing, describing his career trajectory starting as an Assistant Spinning Manager at Universal Textiles, Inc. (UTEX) in 1956. He became a Senior Manager until 1980, later absorbed by Peggy Mills, Inc. (a corporation formed by Lim in 1978 with Filsyn). By the time of his retirement in late 1993, McLeod was earning a monthly salary of P60,000. He outlined various claims of
Case Digest (G.R. No. 216492)
Facts:
- Background of the Case
- John F. McLeod filed a complaint on February 2, 1995, seeking various monetary benefits including retirement, vacation and sick leave, holiday pay, underpayment of salary and 13th month pay, as well as claims for moral and exemplary damages and attorney’s fees.
- McLeod alleged that he was an expert in textile manufacturing who began his career in 1956 at Universal Textiles, Inc. (UTEX) and later became Senior Manager under President Patricio Lim until 1980.
- In 1978, Patricio Lim formed Peggy Mills, Inc. (PMI) with controlling interest held by Filipinas Synthetic Fiber Corporation (Filsyn), and McLeod was absorbed into Peggy Mills as its Vice President and Plant Manager in Sta. Rosa, Laguna.
- Claims Regarding Employment and Benefits
- McLeod contended that at the time of his retirement he received a monthly salary of P60,000 which included a package of benefits (vacation and sick leaves, 13th month pay, holiday pay, and two round-trip business class tickets on a Manila-London-Manila itinerary every three years that could be converted into cash when unused).
- He further alleged that from January 1986 respondents failed to pay due vacation and sick leave credits; similarly, holiday pay was not paid as provided by the collective bargaining agreement (CBA).
- McLeod also asserted that amid the union strike in 1989 and the illegal strike findings in 1993, other employment benefits – including unused airline ticket benefits for the period 1989 to 1992 – were not rendered, while his monthly salary was reduced by P9,900 from August 1990 through November 1993.
- Corporate Restructuring and Employment Status
- In 1991, Filsyn sold Peggy Mills, Inc. to Far Eastern Textile Mills, Inc. (FETMI), with the entity renamed Sta. Rosa Textiles, Inc. (SRTI). McLeod maintained that he continued to work with the new entity, a fact he alleges is evidenced by correspondence and his continual service until November 30, 1993.
- McLeod maintained that he never accepted a change in his status from full-time managerial employee to consultant, and that all benefits and his employment status should be recognized as under PMI, the sole employer with whom he had an employment contract.
- Respondents’ Position and Counterclaims
- The respondents argued that McLeod was employed only with Peggy Mills, Inc. and that the other companies (Filsyn, FETMI, and SRTI) did not have an employment relationship with him.
- They contended that after the closure of Peggy Mills’ operations due to irreversible losses resulting from a union strike, McLeod’s engagement with SRTI was merely as a consultant without any contractual or evidentiary basis proving an employer-employee relationship.
- Respondents also maintained that certain benefits claimed by McLeod (such as unpaid airline tickets and the 13th month pay for 1993) were either already included in his salary package or not part of any established company practice.
- In addition, several counterclaims for damages amounting to P36,757.00 were interposed, intended to offset McLeod’s claims.
- Judicial Proceedings Leading to the Court of Appeals Decision
- The Labor Arbiter rendered a decision on April 3, 1998, awarding McLeod various benefits computed against the respondents, including retirement benefits, underpayment of salary, vacation and sick leave, holiday pay, underpayment of 13th month pay, moral and exemplary damages, attorney’s fees, and an unsettled claim for unused airline tickets.
- On December 29, 1998, the NLRC reversed the Arbiter’s decision aside from retirement benefits, ordering only payment of retirement pay for 12 years of service at a computed rate based on a reduced salary of P50,495 per month, dismissing other claims for lack of merit.
- McLeod then filed a petition for certiorari with the Court of Appeals, challenging the NLRC’s ruling and alleging that all respondent corporations were essentially one and the same, thus solidarily liable for his claims.
Issues:
- Existence of an Employer-Employee Relationship
- Whether McLeod was employed as a managerial employee of Peggy Mills, Inc. and, by extension, whether any employment relationship existed with FETMI, SRTI, or Filsyn.
- Whether the change from a full-time managerial role to a consultant status (if any) established any additional benefits or claims.
- Applicability of the Doctrine of Piercing the Corporate Veil
- Whether the similarities in address, the interlocking directors, and the common counsel among the respondents justify treating the companies as a single corporate entity.
- Whether there is clear and convincing evidence that the separate corporate personalities of PMI, FETMI, SRTI, and Filsyn were being used to shield the true obligations, particularly in respect to McLeod’s claims.
- Entitlement to Benefits and Monetary Claims
- Whether McLeod is entitled to the full array of benefits claimed (retirement pay, vacation and sick leave, holiday pay, underpayment of salary, and 13th month pay).
- Whether the monetary claims should be offset by counterclaims asserted by the respondents.
- The propriety of the awards for moral and exemplary damages and attorney's fees given the circumstances.
- Procedural and Evidentiary Requirements
- Whether the respondents’ filing and service of the memorandum of appeal complied with the mandatory procedural requirements under the Labor Code.
- Whether McLeod’s allegations, lacking corroborative documentary evidence (such as employment contracts or appointment letters from FETMI, SRTI, or Filsyn), are sustainable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)