Case Digest (G.R. No. 116123) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sergio F. Naguiat, Doing Business Under the Name and Style Sergio F. Naguiat Ent., Inc., & Clark Field Taxi, Inc. v. NLRC, et al. (G.R. No. 116123, March 13, 1997), petitioner Clark Field Taxi, Inc. (“CFTI”) held a concessionaire’s contract with the Army Air Force Exchange Services (“AAFES”) to operate taxi services inside Clark Air Base. Sergio F. Naguiat served as CFTI’s president, and his son Antolin T. Naguiat as vice-president, while Sergio F. Naguiat Enterprises, Inc. (“Naguiat Enterprises”) was a separate family trading firm. Individual respondents, former CFTI taxi drivers, paid daily “boundary fees” (US$26.50–27.00) and bore vehicle maintenance costs, earning at least US$15.00 per day. On November 26, 1991, the U.S. military base phase-out terminated AAFES and CFTI operations. The drivers’ union negotiated a P500.00 per year service severance, which most accepted. A dissident group disaffiliated, joined the National Organization of Workingmen (“NOWM”), and through NO Case Digest (G.R. No. 116123) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Operation and employment
- Clark Field Taxi, Inc. (CFTI) held an AAFES concession at Clark Air Base; Sergio F. Naguiat was president and Antolin T. Naguiat vice-president.
- Taxi drivers paid a daily “boundary fee” (US$26.50–27.00), bore vehicle expenses, and earned at least US$15.00/day; excess earnings were deposited bi-monthly.
- Closure and negotiated separation benefits
- Clark Air Base closed November 26, 1991, due to U.S. base phase-out; AAFES dissolved and drivers’ services terminated.
- AAFES Taxi Drivers Association negotiated P500/year of service severance; most drivers accepted, but some disaffiliated, joined NOWM, and refused the amount.
- Administrative and judicial proceedings
- Individual respondents (through NOWM) filed complaints for separation pay against CFTI, Naguiat Enterprises, AAFES and the drivers’ union.
- Labor Arbiter awarded P1,200/year of service “for humanitarian consideration,” rejecting CFTI’s force-majeure defense.
- NLRC modified: granted separation pay at US$120/year of service (peso equivalent) and held Sergio F. and Antolin Naguiat Enterprises jointly and severally liable with CFTI.
- Petitioners sought certiorari under Rule 65, arguing jurisdictional excess, invalid representation, improper corporate/officer liability, and denial of due process.
Issues:
- Did the NLRC commit grave abuse of discretion or act without jurisdiction by increasing separation pay?
- Can NOWM validly represent the individual respondents?
- Is the joint and several liability of Naguiat Enterprises and its officers contrary to law?
- Were Sergio F. and Antolin Naguiat denied due process for not being impleaded?
- Did petitioners waive objections to insufficient copies of the respondents’ NLRC appeal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)