Case Digest (G.R. No. 116123)
Facts:
Sergio F. Naguiat, doing business under the name and style Sergio F. Naguiat Ent., Inc., & Clark Field Taxi, Inc., G.R. No. 116123, March 13, 1997, Supreme Court Third Division, Panganiban, J., writing for the Court.Petitioner Clark Field Taxi, Inc. (CFTI) was the concessionaire under a contract with the Army Air Force Exchange Services (AAFES) to operate taxi services within Clark Air Base. Sergio F. Naguiat was CFTI’s president and Antolin T. Naguiat its vice-president; Sergio F. Naguiat Enterprises, Inc. was a separate family-owned trading corporation. The private respondents were taxi drivers who worked under arrangements that required them to pay daily "boundary fees" (US$26.50–US$27.00) and to bear incidental vehicle expenses; drivers reported earnings of not less than US$15.00 daily and deposited cash excesses with the company.
With the phase-out of U.S. bases and the dissolution of AAFES, the drivers’ services were terminated on November 26, 1991. The drivers’ union (AAFES Taxi Drivers Association) and CFTI negotiated a P500-per-year-of-service severance which many drivers accepted, but the private respondents disaffiliated from the union, joined the National Organization of Workingmen (NOWM), and filed a complaint for separation pay alleging monthly take-home pay of not less than US$240 and asserting regular employment with Naguiat Enterprises though applications were approved by CFTI.
The labor arbiter found the complainants to be regular employees of CFTI and ordered CFTI to pay P1,200.00 per year of service "for humanitarian consideration," rejecting CFTI’s claim that closure was due to great financial losses from Mt. Pinatubo and the base phase-out. On appeal the National Labor Relations Commission (NLRC), Third Division, modified the award and granted separation pay computed at US$120.00 (one-half of the alleged US$240.00 monthly) per year of service (or its peso equivalent) and held Sergio F. Naguiat Enterprises, Inc., Sergio F. Naguiat, and Antolin T. Naguiat jointly and severally liable with CFTI. The NLRC denied petitioners’ motion for reconsideration.
Petitioners filed a petition for certiorari under ...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion amounting to lack of jurisdiction in increasing the separation pay award?
- Could Messrs. Teofilo Rafols and Romeo N. Lopez (and NOWM) validly represent the private respondents?
- Are Sergio F. Naguiat Enterprises, Inc., Sergio F. Naguiat, and Antolin T. Naguiat jointly and severally liable with CFTI for the separation pay?
- Were petitioners denied due process when corporate officers were held personally liable despite not being impleaded, and were petitioners d...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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